### Santa Barbara County Air Pollution Control District

STAFF REPORT

– June 21, 2012

REVISIONS TO

RULE 330. SURFACE COATING OF METAL PARTS AND PRODUCTS

RULE 337. SURFACE COATING OF AEROSPACE VEHICLES AND COMPONENTS

RULE 349. POLYESTER RESIN OPERATIONS

RULE 353. ADHESIVES AND SEALANTS

RULE 321. SOLVENT CLEANING MACHINES AND SOLVENT CLEANING

BACKGROUND

The Santa Barbara County Air Pollution Control District (District) proposes amendments to Rules 330, 337, 349, and 353 to implement new solvent cleaning requirements. The adoption of the new provisions will reduce reactive organic compound emissions and fulfill clean air plan commitments. Slight changes to Rule 321 are also proposed for rule consistency.

The District first adopted Rule 330 in 1979 as,

“ Surface Coating of Manufactured Metal Parts. ” In2000, we amended Rule 330 in response to USEPAidentified deficiency items.

Rule 337 (adopted 1990) fulfilled a 1989 mandate that aircraft and aerospace coatings be controlled at

the limitations outlined in the USEPA Control Techniques Guidelines for Surface Coating of

Miscellaneous Metal Parts and Products . The last significant amendments made to Rule 337 occurred

in 1994. Rule 349 (polyester resin operations, adopted 1993) and Rule 353 (adhesives and sealants, adopted 1999) largely follow guidelines from the California Air Resources Board (ARB). a 

### The current rulemaking

action creates the first amendments to Rule 349 and

353.

The U.S.EPA approved Rules 321, 330, 337, 349, and 353 for inclusion into the State Implementation Plan on May 20, 2011; June 8, 2000; February 12, 1996; January 6, 1995; and April 5, 2000; respectively.

a 

### Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Polyester Resin Operations (1991) and Adhesives and Sealants (1998).

PROPOSED REVISIONS

Appendices A through G contain annotated proposed amended rules (PARs). Four operation-specific rules are being amended to include similar general solvent cleaning provisions found in Rule 321, Solvent Cleaning Machines and Solvent Cleaning (adopted September 20, 2010). This approach provides owners and operators with general solvent cleaning provisions within the rule spec ific to their operations.

The general solvent cleaning provisions are in three categories: 1) work practices, 2) reactive organic compound (ROC) content limits, and 3) solvent cleaning devices/methods. We are also adding rule exemptions and other provisions that parallel Rule 321 (e.g., recordkeeping, source testing, and compliance schedule).

These PARS are anticipated to prompt operators to switch to lower ROC solvents to meet lower ROC solvent content limits specified in the rules. As in Rule 321, to preclude an unintended consequence of switching over from non-toxic to toxic solvents these

PARs define solvent to include any liquid containing any ROC or toxic air contaminant.

Staff considered provisions in other air districts rules when drafting the PARs. These included the South Coast Air Quality Management District (SC), the San Joaquin Unified Valley Air Pollution Control District (SJV), and the Ventura County APCD (VC) rules.

We also considered:

x comments from the USEPA and ARB on prior

rules; and

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page 2 June 21, 2012

Santa Barbara County APCD

x input from the regulated community; and

x federal policies, guidance documents, and

regulations.

This rulemaking project also includes modifications to Rule 102 (Definitions) and Rule 202 (Exemptions to Rule 201). Amendments to these rules are needed for uniformity, updating, and improved rule clarity.

The District expects the proposed revisions will result in about 8 tons per year of ROC emission reduction in Santa Barbara County (on top of the 192 tons per year to be realized from Rule 321 adopted September 20, 2010). The cost-effectiveness of the amended rules range between about -$5,000 (cost saving) to $4,700 per ton of ROC reduced.

The proposed amended rules incorporate the

District's Clean Air Plan ’s proposed control measures to attain the California ozone ambient air quality standard. These PARs provide for expeditious implementation of every feasible measure to reduce ozone precursor emissions.



## Summarized Amendments

RULE 102, DEFINITIONS

Add:

x an enclosed cleaning system definition,

x an exempt compound definition,

x chemical names to the fluorinated gases

definition,

x four USEPA-identified exempt compounds to the

reactive organic compound definition, and

x terms common to the proposed amended rules.

RULE 202, EXEMPTIONS TO RULE 201

Replace EPA Method 24 with South Coast AQMD Method 313-91. Also make minor revisions (e.g., add rule and test method titles).

RULE 321, SOLVENT CLEANING MACHINES

AND SOLVENT CLEANING

Revise the Section B.6 exemption to clarify that the exemption does not apply to solvent cleaning machines when an operation-specific rule indicates such equipment is subject to Rule 321.

RULE 330, SURFACE COATING OF METAL

PARTS AND PRODUCTS

Add Rule 321-type exemptions, definitions, and general solvent cleaning, re cordkeeping, reporting, source testing, and compliance provisions.

RULE 337, SURFACE COATING OF

AEROSPACE VEHICLES AND COMPONENTS

In addition to the changes ou tlined for Rule 330, add:

1. Adhesive and sealant provisions; and 2. Coating categories and limits from a USEPA Control Techniques Guideline (CTG) document and a federal regulation for the source category. 1


### The District is also lowering the stripper ROC limit from 400 to 300 grams per liter in response to suggestions by the ARB and the USEPA.

RULE 349, POLYESTER RESIN OPERATIONS

The changes outlined for Rule 330 were included in PAR 349. Lower polyester resin material monomer contents limits and a higher add-on control equipment overall efficiency limit were also added. These new provisions have a 24-month phase-in period to allow for product sale-through and available stock depletion. Lastly, staff made minor changes to

the rule’s Attachment A, “Static Method for Determination of Volatile Emissions from Polyester and Vinyl Ester Resins. ”

RULE 353, ADHESIVES AND SEALANTS

Amend to include Rule 321-type provisions like in the other rules. Add application equipment requirements and stripper use provisions. Reduce the ROC-content limit on several products.



## Sources that May be Affected by the

Amended Rules

These are in four general categories:

I. Sources subject to Rule 330 that surface coat (paint) metal parts and products (excludes architectural coating operatio ns subject to Rule 323 and motor vehicle coating operations subject to Rule 339). II. Sources subject to Rule 337 that surface coat aerospace vehicles and components (excludes electronic components, but includes aircraft adhesive and sealant surface coating).

1 

### The June 2009 USEPA Technical Support Document for the San Joaquin Valley APCD, Rule 4604, Aerospace Assembly and Component Coating Operations, found the rule deficient for failing to include all of the coating categories in the CTG. Hence, to avoid a similar deficiency finding, PAR 337 includes additional categories from the CTG.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page 3 June 21, 2012

Santa Barbara County APCD III. Any person subject to Rule 349 that owns or operates a commercial or industrial polyester resin operation. IV. Sources subject to Rule 353 that use adhesives and sealants (includes construction contractors but not adhesives and sealants subject to the consumer product regulations).

Table 1 lists the sources that may be impacted by the

amended rules.

Table 1. SOURCES THAT MAY BE AFFECTED

BY THE AMENDED RULES

Company/Agency Rule(s) the Source May be Subject to (Denoted by an “X” )

330 337 349 353
AmRich Energy X X X

Anderson Custom Boats X

Armelin X X X

Art-Craft Paint, Incorporated X

Astro Aerospace X

Atlas, Caliente #1 and #2

Wells X X X

Atlas Copco Mafi-Trench Company LLC X

Beatty Products X

BEGA/US X

Blair Lease #2 - Sierra

Resources X X X

Bob Haakenson Fiberglass X

C&D Zodiac X X
Careaga #1 X X X
Careaga LA #2 X X X

Casmalia X X X

Castillo Ross & Howe Lease X X X

Channel Islands Surfboards X

Clark Avenue Source X X X

Continental X X X
Conway (Various) X X X
Dos Cuadras - South County X X X
E & B - South County X X X
ERG Resources (Various) X X X
Exxon - New Cuyama X X X
Exxon - SYU Project X X X

Federal Correctional

Institution X

Forms and Surfaces X X

Four Seasons Biltmore X
Gato Ridge X X X
Gilxco - Williams Holding X X X Company/Agency Rule(s) the Source May be Subject to (Denoted by an “X” )

330 337 349 353
Gitte-Ten/Phoenix Energy X X X
Glassaire Repair X
Greka (Various) X X X

Harbor Marineworks X
Kirby Morgan Dive Systems X
Lundberg & Vickery X

Lockheed Martin - SB Focalplane X X X

Lompoc Unified School

District X

Los Flores X X X
MarBorg Industries X

Melfred Borzall, Inc. X
MorningStar Surfboards X
Off Broadway Mineral X X X

Orcutt X X X
Orcutt Pump Station X X X

Outer Reef X
Pacific Coast Energy Company X X X

Pacific Operators - Carpinteria X X X

Pacific Pipeline -Cuyama Pump Station X X X

Panther Energy X X X

Permacolor, Inc. X

Petroleum Solids Control -

Various Loc. X X X

PetroRock - Travis Lease X X X

PetroRock - Tunnell Lease X X X
Plains Pipeline, L.P. X X X

Platform Habitat X X X
Pt. Pedernales/Lompoc Oil

Fields X X X

Purisima Hills LLC - Blair

Lease X X X

Purisima Hills LLCBarham Ranch X X X

Pyramid - Delaney/Tunnel X X X
Pyramid Tile X
Raytheon Space & Airborne Systems X X X

Russell Ranch Lease X X X

Santa Barbara Industrial Finishing X

Santa Barbara School

Districts X

Santa Maria Pacific -

Casmalia Field NW X X X

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page 4 June 21, 2012

Santa Barbara County APCD Company/Agency Rule(s) the Source May be Subject to (Denoted by an “X” )

330 337 349 353
Santa Maria Pump Station X X X

Sierra Resources, Incorporated X X X

Sisquoc Pipeline X X X
SMRC/Union Sugar X X X

SMV East X X X

So Cal Gas - La Goleta X X X
Space Exploration Technologies X

Spaceport Systems

International X

The Okonite Company X X
The Point Arguello Project X X X
True Ames Fins Corporation X Company/Agency Rule(s) the Source May be Subject to (Denoted by an “X” )

330 337 349 353

United Launch Alliance,

L.L.C X

University of California -

Santa Barbara X X X

Vandenberg Air Force Base X X X X
Venoco (Various) X X X
Westmont College X X X

Zaca Field X X X

There are likely additional permit-exempt sources not listed in Table 1, which will also be affected by the PARs. It should be noted that although oil and gas production and process facilities appear in Table 1, industry representatives indicate the amended rules will have limited applicability and impacts to them.

EMISSION REDUCTION / COST-EFFECTIVENESS

ROC Emission Reductions

The District anticipates the ROC emission reductions from adding solvent cleaning provisions to the rules will be about 8 tons per year. Table 2 breaks down the ROC emission

reductions for each of the control measures.

Table 2. ITEMIZED EMISSIONS

REDUCTIONS

Rule (Control Measure) ROC Emission Reductions (TPY)

Rule 330/337 (R-SC-2) 5.7931

Rule 349 (R-SL-5) 0.9526

Rule 353 (R-SL-9) 1.5759

Total 8.3216

Due to changes in the project, activity factors, and the inventory, the currently projected emission reductions for calendar year 2020 are about 7 percent less than those indicated in the 2010 Clean Air Plan. This difference equates to about 5 pounds per day. Irrespective of the change in the ROC emission reductions, the amended rules need to be adopted to fulfill the CAP commitment and to adopt every feasible measure.

Cost-Effectiveness

The cost-effectiveness of switching from a highROC solvent to a low-ROC solvent ranges between -$5,308 (savings) and $4,744 per ton

of ROC reduced. And the cost-effectiveness of using an enclosed solvent cleaning system or acetone when cleaning application equipment ranges from $776 to $1,888 tons of

ROC reduced.

Table 3 shows the summarized costeffectiveness data for four scenarios.

Table 3. COST-EFFECTIVENESS DATA

Scenario Cost Effectiveness Range (Dollars per

Ton of ROC

Reduced) 1. 100% replacement with aqueous solvents -5,308 to -146 (cost savings)

2. 20% replacement with acetone, 80% replacement with aqueous solvents 418 to 699

3. 100% replacement with

acetone. -3,548 to 4,744

4. Cleaning application equipment with an enclosed gun washer or replacing an ROC solvent

with acetone. 776 to 1,888

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page 5 June 21, 2012

Santa Barbara County APCD Incremental Cost-Effectiveness

Health and Safety Code Section 40920.6 requires an incremental cost-effectiveness analysis for a regulation that identifies more than one control option to meet the same emission reduction objectives. Incremental cost-effectiveness is defined as the difference in costs divided by the

difference in emission reductions between one level of control and the next more stringent

level of control.

The amended rules regulate solvent cleaning. Compliance by operation modifications and the substitution of materials is expected. No

alternative emission control scenario is

available.

ANALYSIS OF EXISTING FEDERAL AND DISTRICT REGULATIONS

Appendix H contains the written analysis required by the California Health & Safety Code Section 40727.2 requirements.

COMMENTS AND PUBLIC MEETINGS

Comments

The District received and re sponded to an extensive volume of comments on the proposed amended rules during the development stages. Staff consolidated these comments and responses into Appendix I,

Clarification of Rule Issues. Comments received during the formal public comment period preceding the Board adoption hearing on the proposed rule changes and sta ff’s response to these comments will be presented to the District Board of Directors as part of the rule adoption process.

Public Meetings

SCOPING WORKSHOPS, FEBRUARY 10, 2011

Staff explained that solvent cleaning provisions, similar to those in Rule 321, were being added to

each of the rules. Attendees asked if we were changing the requirements on solvents used for stripping, thinning, and solvent welding. Staff responded during the meeting that the current as applied limits for those operations were not being changed, only the solvent cleaning provision were being added or modified.

Industry spokespersons asked that the rule

modifications:

1. Add aerospace adhesives to Rule 337 and make the Rule 353 aerospace adhesive exemption less ambiguous, 2. Include uniform definitions between the rules, 3. Provide provisions for reworking and unglueing parts, and 4. Allow isopropyl alcohol to be used as a solvent on aerospace ground support equipment.

Rulemakers considered and addressed these requests in the proposed amended rules. However, it should

be noted that ARB and USEPA comments received after the Scoping Workshop recommended reducing the stripper ROC content limit from 400 to 300 grams per liter. The District has revised the project to include this change.

WORKSHOP AND COMMUNITY ADVISORY COUNCIL MEETING, AUGUST 10, 2011

The District conducted a public workshop on August 10, 2011. A number of concerns were raised at the workshop (e.g., rule clarity, scope of applicability, and need for certain rule revisions). During the subsequent Community Advisory Council (CAC) meeting, additional concerns were raised. Hence, the CAC continued the item to allow staff to develop revised rules and to provide documentation in support of the proposed rule amendments.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page 6 June 21, 2012

Santa Barbara County APCD STAKEHOLDERS MEETINGS: DECEMBER 12, 2011, JANUARY 10, 2012, MARCH 1, 2012, AND MARCH 19, 2012

Various stakeholder meetings were conducted on these dates to convey in formation on the proposed rule changes and work out possible alternatives. COMMUNITY ADVISORY COUNCIL MEETING, APRIL 11, 2012

The CAC passed a motion to recommend that the Board of Directors approve the proposed amended

rules.

PUBLIC HEARING ON THE ADOPTION OF THE PROPOSED AMENDED RULES, JUNE 21, 2012

The Board is scheduled to consider the adoption of the revised rules at the June 21, 2012 Public Hearing.

COMPARISON OF ADJOINING AIR POLLUTION CONTROL DISTRICT RULES

Appendix J provides a comparison of the San Joaqui n Valley Air Pollution Control District (APCD), Ventura County APCD, and the San Luis Obispo County APCD rule s on permit exemptions and requirements for solvent cleaning machines and solvent cleaning. Basically, there are general similarities with some minor differences between the adjoining air district rules and the proposed amended rules.

IMPACTS OF THE REVISED RULES TO INDUSTRY AND THE DISTRICT

Details of the impacts from the rule revisions are summarize d in Appendix K. The rule revisions will cause impacts to the regulated community and District staff by:

1. Expanding the scope of applicability of the rules to include 1) solvent cleaning that is associated with the operation-specific rules, and 2) solvents that contain toxic air contaminants. 2. Requiring changes to the methods of operation to comp ly with the new solvent cleaning requirements (e.g., use of enclosed cleaning systems when performing solvent cleaning of application equipment). 3. Lowering the ROC-content limits on Rule 349 polyester resin materials and three Rule 337 coatings. 4. Increasing recordkeeping provisions.

APPENDICES 1



### Appendix A : Annotated Proposed Amended Rule 102, Definitions Appendix B : Annotated Proposed Amended Rule 202, Exemptions to Rule 201 Appendix C : Annotated Proposed Amended Rule 321, Solven t Cleaning Machines and Solvent Cleaning Appendix D : Annotated Proposed Amended Rule 330, Surface Coating of Metal Parts and Products Appendix E : Annotated Proposed Amended Rule 337, Surface Coating of Aerospace Vehicles and Components Appendix F : Annotated Proposed Amended Rule 349, Polyester Resin Operations Appendix G : Annotated Proposed Amended Rule 353, Adhesives and Sealants Appendix H : Identification of Existing Federal Regulations and Santa Barbara County Air Pollution Control District Regulations that Apply to the Same Equipment or Source Type Covered in Rules 330, 337, 349, and 353 Appendix I : Clarification of Rule Issues Appendix J : Comparison of the Adjoining Air District Rules Appendix K : Impacts from the Revised Rules

1 

### These appendices are hyperlinked.STAFF REPORT

– PARs 330, 337, 349, & 353 Page A-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 102 102 - 1 March 17, 2011 [ date of amended rule adoption ] Appendix A Santa Barbara County Annotated Proposed Amended Rule 102, Definitions

RULE 102. DEFINITIONS. (Adopted 10/18/1971, rev ised 1/12/1976, readopted 10/23/1978, revised 7/11/1989, 7/10/1990, 7/30/1991, 7/18/1996, 4/17/1997, 1/21/1999, 5/20/1999, 6/19/2003, 1/20/2005, 6/19/2008, 1/15/2009, 9/20/2010, 1/20/2011, and 3/17/2011 , and [ date of amended rule adoption ] )

These definitions apply to the entire rulebook. Definitions sp ecific to a given rule are defined in that rule or in the first rule of the relevant regulation. Except as otherwis e specifically provided in these Rules where the context otherwise indicates, words used in these Rules are used in exactly the same sense as the same words are used in Division 26 of the Health and Safety Code.

[. . .]

“Aerosol Product” means a hand-held, non-refillable container that expels pressurized product by means of a propellant-induced force.

[. . .]

“Avionic Equipment” means any electronic system used on any airc raft, aerospace vehicle, satellite, or space

vehicle.

[. . .]

“Capture Efficiency” means the percentage by weight of affec ted pollutants delivered to a control device divided by the weight of total affected pollutants generated by the source.

[. . .]

“Carbon A dsorber” means a bed of activated carbon into which an air-solvent gas-vapor stream is routed and

which adsorbs the solvent on the carbon.

[. . .]

“ Catalytic Incinerator ” means an y device that burns reactive organic compounds or toxic air contaminants in air using a material that increases the rate of combustion without itself undergoing a net chemical change in the process. Common catalyst materials include but ar e not limited to, platinum alloys, chromium, copper oxide, and cobalt.

[. . .]

“Control Device” means any destruction and/or recovery equipm ent used to destroy or recover affected pollutant emissions generated by a regulated operation.

“Control Device Efficiency” means the percentage of affected pollutants entering a control device that is not present in the exhaust to the atmosphere of that control device.

[. . .]

“Electronic Components” means the portions of an assembly, including, but not limited to: circuit card assemblies, printed wire assemblies, printed circuit boar ds, soldered joints, ground wires, bus bars, magnetic tapes and tape drive mechanisms, discs and disc drive mechanisms, electro-optical devices (e.g., optical filters, sensor assemblies, infrared sensors, char ged coupled devices, thermal electric coolers, and vacuum assemblies), solid state components, semiconductors (e .g., diodes, zeners, stacks, rectifiers, integrated Comment [A1]: The term is found in proposed

amended Rules 330, 337, 349, and 353 . To avoid ambiguity, this definition, and other add

- on control equipment definitions (e.g., control device and control device efficiency ), are being added. To avoid redundancy in Rules 330, 337, 349, and 353, the District is adding the definitions to Rule 102.STAFF REPORT

– PARs 330, 337, 349, & 353 Page A-2 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 102 102 - 2 March 17, 2011 [ date of amended rule adoption ] microcircuits, transistors, solar cells, light sensing de vices, and light-emitting devices), and other electrical fixtures, except for the actual cabinet in which the components are housed.

“Electrostatic Spray” means any method of applying a spray coating in which an electrical charge is applied to the coating and the substrate is grounded. The co ating is attracted to the substrate by the electrostatic potential between them.

[. . .]

“Enclosed Cleaning System” means any application equipment cleaner (e.g., an enclosed gun washer) that totally encloses spray guns, cups, nozzles, bowls, and other parts during solvent washing, rinsing, and draining procedures. An enclosed cleaning system for cleaning application equipment is not a solvent cleaning machine.

[. . .]

“Exempt Compound” means any compound listed as an exempt compound in the definition of “ Reactive Organic Compound. ” Tertiary-butyl acetate (also known as t-butyl acetate or tBAc) shall be considered exempt as a reactive organic compound only for purp oses of reactive organic compound emissions limitations or reactive organic compound content requirements and shall be considered a reactive organic compound for purposes of all recordkeeping, emissions reporting, photochemical dispersion modeling, and inventory requirements which apply to reactive organic compounds.

[. . .]

“Fluid System” means a power transmission system that uses the force of flowing liquids and gases to transmit power. Fluid systems include hydraulic systems and pneumatic systems.

“Fluorinated Gases” means a compound that contains fluorine and exists in a gaseous state at 25 degrees Celsius and 1 atmosphere of pressure. Fluori nated gases include, but are not limited to:

1. hexafluoroethane (C 2 F 6 ), (CFC-116), 2. octafluoropropane (C 3 F 8 ), (PFC 218), 3. octafluorocyclopentene (C 5 F 8 ), (PFC C-1418), 4. tetrafluoromethane (CF 4 ), (CFC-14), 5. trifluoromethane (CHF 3 ), (HFC-23), 6. difluoromethane (CH 2 F 2 ), (HFC-32), 7. octafluorocyclobutane (c-C 4 F 8 ), (RC 318), 8. octafuorotetrahydrofuran (C 4 F 8 O), 9. hexafluoro-1,3-butadiene (C 4 F 6 ), 10. carbon fluoride oxide (COF 2 ), 11. nitrogen trifluoride (NF 3 ), and 12. sulfur hexafluoride (SF 6 ).

[. . .]

“Grams of Reactive Organic Compound Per Liter of Material” means the weight of reactive organic compound per volume of material and can be calculated by the following equation:

W

s - W

w - W

e Grams of reactive organic compounds per liter of material = V

m

Where: W

s = Weight of volatile compounds in grams

W

w = Weight of water in grams

W

e = Weight of exempt compounds in grams Comment [A2]: This definition is being added per requests from industry. The term appears in current Rule 321 and PARs 337 and 353. Hence, we are placing the definition in Rule 102.

Comment [A3]: Adding the exempt compound

definition here eliminates the need to insert the same definition into other rules. The tBAc qualifier

addresses EPA concerns.

Comment [A4]: Adding chemical names here follows the protocol used in the exempt compound

list within the reactive organic compound

definition.STAFF REPORT

– PARs 330, 337, 349, & 353 Page A-3 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 102 102 - 3 March 17, 2011 [ date of amended rule adoption ] V

m = Volume of material in liters

[. . .]

“High

- Precision Optics” means any optical element used in an electro-optical device that is designed to sense, detect, or transmit light energy, including speci fic wavelengths of light energy and changes in light energy levels.

[. . .]

“Natural Draft Opening” means any opening in a room, building, or total enclosure that remains open during operation of the facility and that is not connected to a du ct in which a fan is installed. The rate and direction of the natural draft through such an opening is a consequence of the difference in pressures on either side of the wall containing the opening.

[. . .]

“Operating Parameter Value” means any minimum or maximum value established for a control equipment or process parameter which, if achieved by itself or in combination with one or more other operating parameter values, determines that an owner or operator ha s continued to comply with an applicable emission

limitation.

[. . .]

“Overall Efficiency” means the emission reduction, expressed as a percentage that results from the combined effect of capture and control of affected pollutants (capture efficiency multiplied by control efficiency).

[. . .]

“Photoresist Coating” means any coating applied directly to a substrate to protect surface areas when chemical milling, etching, or other chemical surface operations are performed on the substrate.

[. . .]

“ Reactive Organic Compound” means any compound containing at least one (1) atom of carbon, except for the following exempt compounds:

1. acetone

2. ammonium carbonate

3. carbon dioxide

4. carbon monoxide

5. carbonic acid
6. dimethyl carbonate

7. ethane

8. metallic carbides or carbonates

9. methane
10. methyl acetate
11. methyl chloroform (1,1,1-trichloroethane)
12. methyl formate; HCOOCH 3 13. cyclic, branched, or linear completely methylated siloxane compounds
14. methylene chloride
15. parachlorobenzotrifluoride
16. perchloroethylene (tetrachloroethylene)
17. the following four classes of perfluorocarbon (PFC) compounds:STAFF REPORT

– PARs 330, 337, 349, & 353 Page A-4 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 102 102 - 4 March 17, 2011 [ date of amended rule adoption ] a. cyclic, branched, or linear, completely fluorinated alkanes, b. cyclic, branched, or linear, completely fluo rinated ethers with no unsaturations, c. cyclic, branched, or linear, completely fluorina ted tertiary amines with no unsaturations,

and d. sulfur containing perfluorocarbons with no unsaturations and with sulfur bonds only to

carbon and fluorine.

18. propylene carbonate
19. tertiary-butyl acetate; C 6 H 12 O 2 (“acetic acid, 1,1

- dimethylethyl ester”)

Tertiary-butyl acetate (also known as t-butyl ace tate or tBAc) shall be considered exempt as a reactive organic compound only for purposes of reactive organic compound emissions limitations or reactive organic compound content requirements and will continue to shall be considered a reactive organic compound for purposes of all recordkeeping, emissions reporting, photochemical dispersion modeling, and inventory requirements which apply to reactive organic compounds.

20. CFC-11 (trichlorofluoromethane)

21. CFC-12 (dichlorodifluoromethane)
22. CFC-113 (1,1,2-trichloro-1,2,2-trifluoroethane)
23. CFC-114 (1,2-dichloro 1,1,2,2-tetrafluoroethane)
24. CFC-115 (chloropentafluoroethane)
25. HCFC-22 (chlorodifluoromethane)

26. HCFC-31 (chlorofluoromethane)
27. HCFC-123 (1,1,1-trifluoro 2,2-dichloroethane)

28. HCFC-123a (1,2-dichloro-1,1,2-trifluoroethane)
29. HCFC-124 (2-chloro-1,1,1,2-tetrafluoroethane)

30. HCFC-141b (1,1-dichloro 1-fluoroethane)
31. HCFC-142b (1-chloro-1,1 difluoroethane)
32. HCFC-151a (1-chloro-1-fluoroethane)
33. HCFC-225ca (3,3-dichloro-1,1,1,2,2-pentafluoropropane)
34. HCFC-225cb (1,3-dichloro-1,1,2,2,3-pentafluoropropane)
35. HFC-23 (trifluoromethane)
36. HFC-32 (difluoromethane)
37. HFC-43-10mee (1,1,1,2,3,4,4,5,5,5-decafluoropentane)
38. HFC-125 (pentafluoroethane)

39. HFC-134 (1,1,2,2-tetrafluoroethane)
40. HFC-134a (1,1,1,2-tetrafluoroethane)
41. HFC-143a (1,1,1-trifluoroethane)
42. HFC-152a (1,1-difluoroethane)
43. HFC-161 (ethylfluoride)
44. HFC-227ea (1,1,1,2,3,3,3-heptafluoropropane)

4 45 . HFC-236ea (1,1,1,2,3,3-hexafluoropropane)

4 56 . HFC-236fa (1,1,1,3,3,3-hexafluoropropane)

4 67 . HFC-245ca (1,1,2,2,3-pentafluoropropane)

4 78 . HFC-245ea (1,1,2,3,3-pentafluoropropane)

4 89 . HFC-245eb (1,1,1,2,3-pentafluoropropane)

4950 . HFC-245fa (1,1,1,3,3-pentafluoropropane)

5 01 . HFC-365mfc (1,1,1,3,3-pentafluorobutane)

52. HFE-7000; n-C 3 F 7 OCH 3 ; (1,1,1,2,2,3,3-heptafluoro-3-methoxy-propane)

5 13 . HFE-7100; (CF 3 ) 2 CFCF 2 OCH 3 ; (2-(difluoromethoxymethyl)-1,1,1 ,2,3,3,3-heptafluoropropane) or

C 4 F 9 OCH 3 ; (1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy-butane) Comment [A5]: EPA’s definition of volatile organic compounds in 40 CFR, Part 51.100(s)

includes HFC

- 227ea. The same is true for the other compounds we are adding (52, 55, and 56).STAFF REPORT

– PARs 330, 337, 349, & 353 Page A-5 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 102 102 - 5 March 17, 2011 [ date of amended rule adoption ] 5 24 . HFE-7200; (CF 3 ) 2 CFCF 2 OC 2 H 5 ; (2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-heptafluoropropane) or

C 4 F 9 OC 2 H 5 ; (1-ethoxy-1,1,2,2,3,3,4,4,4-nonafluorobutane)

55. HFE-7300; ((1) 1,1,1,2,2,3, 4,5,5,5-decafluoro-3-methoxy- 4-trifluoromethyl-pentane)
56. HFE-7500; (3-ethoxy- 1,1,1,2, 3,4,4,5,5,6,6,6-dodecafluoro-2- (trifluoromethyl) hexane)

Rule 202.D.10.l.1 requires an Authority to Construct an d Permit to Operate when using more than one gallon per year per stationary source of any one of the following exempt compounds:

(6) dimethyl carbonate, (37) HFC-43-10mee,

(12) methyl formate, (50) HFC-245fa,

(33) HCFC-225ca, (51) HFC-365mfc, or

(34) HCFC-225cb, (53) HFE-7100 [(CF 3 ) 2 CFCF 2 OCH 3 or C 4 F 9 OC 2 H 5 ]

Rule 202.D.10.l.2 requires an Authority to Construct an d Permit to Operate when using more than one gallon per year per stationary source of : (19) tertiary-butyl acetate.

The one gallon per year per stationary source limit is a per compound limit for each compound in aggregate for the entire stationary source and includes any amount s of the compound used in mixed or diluted product.

“Reactive Organic Compound Composite Partial Pressure” means the sum of the partial pressures of compounds defined as reactive organic compounds. Re active organic compound composite pressure shall be

calculated as follows:



# ¦ ¦ ¦

  n

e n

1 i i i e e w w i n

i i i

c

MW W MW W MW W MW VP W

PP

1 1

/ / / /

Where: W i = Weight of the “i”th reactive organic compound, in grams

W

w = Weight of water, in grams

W

e = Weight of the “e”th exempt compound, in grams

MW i = Molecular weight of the “i”th reactive organic compound, in grams per grams -mole

MW

w = Molecular weight of water, in grams per grams-mole

MW

e = Molecular weight of the “e”th exempt compound, in grams per grams -mole

PP

c = Reactive organic compound composite partial pressure at 20 degrees Celsius, in millimeters of mercury

VP i = Vapor pressure of the “i”th reactive organic compound at 20 degrees Celsius, in millimeters of mercury

[. . .]

“Scientific Instrument” means an instrument, including the components, assemblies, and subassemblies used in their manufacture, and associated accessories and re agents, that is used for the detection, measurement, analysis, separation, synthesis, or sequencing of various compounds.

[. . .]

“South Coast Air Quality Management District Method 303 -91, “ Determination of Exempt Compounds, ” August 1996, ” means the test method adopted by and in effect by the South Coast Air Quality Management District on [ date of amended rule adoption ].

“ South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, ” means the test method adopted by and in effect by the South Coast Air Quality Management District on [ date of amended rule adoption ].

“Space Vehicle” means any man-made device, either manned or unmanned, designed for operation beyond earth's atmosphere. This definition includes integral equipment such as models, mock-ups, prototypes, Comment [A6]: The data is reformatted into two columns with the compound’s item number added

for ease of reference.STAFF REPORT

– PARs 330, 337, 349, & 353 Page A-6 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 102 102 - 6 March 17, 2011 [ date of amended rule adoption ] molds, jigs, tooling, hardware jackets, and test coupons. Also included is auxiliary equipment associated with test, transport, and storage, which through contamin ation can compromise the space vehicle performance.

[. . .]

“Temporary Total Enclosure” means any total enclosure that is constructed for the sole purpose of measuring the emissions from an affected source that ar e not delivered to an emission control device. A temporary total enclosure must be constructed and ventilated (through stacks suitable for testing) so that it has minimal impact on the performance of the permanent emission capture system. A temporary total enclosure will be assumed to achieve total capture of fugitive emissions if it meets the requirements found in 40 CFR Section 63.750(g)(4) and if all natural draft openings are at least four duct or hood equivalent diameters away from each exhaust duct or hood. Alternatively, the ow ner or operator may apply to the Control Officer for approval of a temporary enclosure on a case-by-case basis.

“ Thermal Incinerator ” means any device that burns reactive organic compounds or toxic air contaminants in air by direct application of heat. Thermal incinerators are usually equipped with burners, refractory lined chambers, heat recovery equipment, and process controllers.

“Total Enclosure” means any permanent structure that is constructed around a gaseous emission source so that all gaseous pollutants emitted from the source ar e collected and ducted through a control device, such that 100 percent capture efficiency is achieved. There are no fugitive emissions from a total enclosure. The only openings in a total enclosure are forced makeup air and exhaust ducts and any natural draft openings

such as those that allow raw materials to enter and exit the enclosure for processing. All access doors or windows are closed during routine operation of the enclosed source. Brief, occasional openings of such doors or windows to accommodate process equipment adjustment s are acceptable, but if such openings are routine or if an access door remains open during the entire op eration, the access door must be considered a natural draft opening. The average inward face velocity across the natural draft openings of the enclosure shall be calculated including the area of such access doors. The drying oven itself may be part of the total enclosure. An enclosure that meets the requirements found in 40 CFR Section 63.750(g)(4) is a permanent total

enclosure.

[. . .]

“Transfer Efficiency” means the ratio of the weight of coating so lids adhering to the object being coated to the weight of coating solids used in the ap plication process, expressed as a percentage.

“Waste Solvent Residue” means sludge that may contain dirt, oil, metal particles, and/or other undesirable waste products concentrated after heat distillation of solvent either in a solvent cleaning machine itself or after distillation in a separate still.

[. . .]

Click here to return to the list of Appendices in the Staff Report.STAFF REPORT

– PARs 330, 337, 349, & 353 Page B-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 202 202 - 1 March 17, 2011[ date of amended rule adoption ] Appendix B Santa Barbara County Annotated Proposed Amended Rule 202, Exemptions to Rule 201

RULE 202. EXEMPTIONS TO RULE 201. (Adopted 10/18/1971, revised 5/1/1972 and 6/27/1977, readopted 10/23/1978, revised 12/7/1987, 1/ 11/1988, 1/17/1989, 7/10/1990, 7/30/1991, 11/05/1991, 3/10/1992, 5/10/1994, 6/28/1994, 4/ 17/1997, 3/17/2005, 1/17/2008, 6/19/2008, 9/20/2010, 1/20/2011, and 3/17/2011 , and [ date of amended rule adoption ] )

[. . .]

C

. Definitions

See Rule 102 , Definitions, for definitions.

D

. General Provisions

[. . .]

5. Temporary Equipment

[. . .]

b. the temporary equipment replaces equipment that has qualified for a breakdown pursuant

to Rule 505 , Breakdown Conditions

.

[. . .]

6. De minimis Exemption

Any physical change in an existing stationary source that meets each of the requirements below is exempt. Emission increases shall be based on th e uncontrolled potential to emit, less emission reductions achieved through Rule 331, Fugitive Emissions Inspection and Maintenance , and shall not be reduced (netted out) by emission reductions achieved through the removal or control of any

component.

[. . .]

9. A permit shall not be required for equivalent rout ine replacement in whole or in part of any article, machine, equipment or other contrivance where a Permit to Operate had previously been granted under Rule 201, Permits Required, providing emissions are not increased and there is no potential for violating any ambient air quality standard. An equivalent piece of equipment has a Potential to Emit, operating design capacity or actual demonstrated capacity less than or equal to that of the original piece of equipment, and is subject to the same limitations and permit conditions as the equipment being replaced. [. . .]

10. Notwithstanding any exemption defined in this rule, no new or modified stationary source that has the potential to emit air contaminants in excess of the amounts specified shall be exempt from permit requirements: [. . .]

l. In addition, notwithstanding any exemption defined in this rule, no stationary source that has the potential to emit any air contaminants in excess of the amounts specified shall be exempt from permit requirements: [. . .]

2. more than one gallon per year of tertiary-butyl acetate; C 6 H 12 O 2 ("acetic acid, 1,1- dimethylethyl ester”). Tertiary -butyl acetate (also known as t-butyl acetate Comment [A7]: Including rule titles for

referenced rules follows an EPA recommendation.STAFF REPORT

– PARs 330, 337, 349, & 353 Page B-2 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 202 202 - 2 March 17, 2011[ date of amended rule adoption ] or tBAc) shall be considered exempt as a reactive organic compound only for purposes of reactive organic compound emissions limitations or reactive organic compound content requirements and will continue to shall be considered a reactive organic compound for purposes of all recordkeeping, emissions reporting, photochemical dispersion modeling, and inventory requirements which apply to reactive organic compounds. The one gallon per year per stationary source limit for tertiary-butyl acetate is an aggregate limit for the entire stationary source and includes any amounts of the compound used in mixed or diluted product.

[. . .]

16. Notwithstanding any exemption in these rules and regulations, if the combined emissions from all construction equipment used to construct a stationary source which requires an Authority to Construct have a projected actual in excess of 25 tons of any pollutant, except carbon monoxide, in a 12 month period, the owner of the stationary so urce shall provide offsets as required under the provisions of Rule 804 , Emission Offsets, and shall demonstrate that no ambient air quality

standard would be violated.

17. No additional permit shall be required at a stationary source in the District for equipment permitted by the District for various location uses provided the following conditions are met:

[. . .]

d. The stationary source reports all uses (inc luding the start and end dates) and associated emissions for each use under this exemption to the APCD District in their next annual report (or semi-annual report for Part 70 sources).

[. . .]

I. Coatings Applications Equipment and Operations

[. . .]

3. Equipment used in surface coating operations provided that the total amount of coatings and solvents used does not exceed 55 gallons per year . Solvents meeting the criteria of Section U.2.b

or Section U.2.c or that have a reac tive organic compound content of 50 grams per liter or less, as determined by the Environmental Protection Agency Reference Method 24South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer , do not contribute to the 55 gallons per year per stationary source limitation. However, such sources need not obtain permits for air pollution control equi pment (i.e., spray booths, carbon adsorbers, incinerators, thermal oxidizers, dust collectors, etc.) unless control equipment is required by District prohibitory rules. For equipment owned or operated by a stationary source owner or operator and used as part of the stationary so urce operations, the 55 gallon per year exemption shall be based on the total coatings and solvents usage of all such equipment at the stationary

source.

[. . .]

U. Solvent Application Equipment and Operations

[. . .]

2. Single solvent cleaning machines, which use unheated solvent, and which: Comment [A8]: Our practice to eliminate

acronyms.

Comment [A9]: EPA recommended referring to

SC Method 313 for d etermining ROC content of materials containing < 50 g/l.STAFF REPORT

– PARs 330, 337, 349, & 353 Page B-3 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 202 202 - 3 March 17, 2011[ date of amended rule adoption ] [. . .]

c. use solvents with a reactive organic compound content of two percent or less by weight as determined by Environmental Protection Agency Method 24 the South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board,

and the Control Officer

.

d. The liquid surface area of any solvent cleaning machine using the following solvent shall not be counted towards the 0.929 square meter (10 square feet) aggregate limit in

subsection a. above:

i. any solvent that has a reactive organic compound content of 50 grams per liter or less, as determined by the Environmental Protection Agency Method 24 South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods appr oved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer,; or [. . .]

3. Wipe cleaning operations, provided that the solven ts used do not exceed 55 gallons per year per stationary source and that the solvent cleaning comp lies with the requirements in Rule 321, Solvent Cleaning Machines and Solvent Cleaning.

To qualify for this exemption, the owner or operator shall maintain records of the amount (gallons per year) of solvents used for wipe cleaning at the stationary source for each calendar year.

These records shall be maintained on site for at le ast 3 years and be made available to the District on request. Thereafter, the records shall be main tained either on site or readily available for expeditious inspection and review for an additional 2 years. Solvents meeting the criteria of 2.b. or c. above or that have a reactive organic com pound content of 50 grams per liter or less, as determined by the Environmental Protection Agency Reference Method 24South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer , do not contribute to the 55 gallons per year per stationary source limitation.

[. . .]

V. Storage and Transfer Equipment and Operations

[. . .]

2. Storage of refined fuel oils with a n American Petroleum Institute gravity of 40 ° degrees API or lower as determined by ASTM D-4057

- 06, “Standard Practice for Manual Sampling of Petroleum and Petroleum Products,” ASTM International

.

[. . .]

Click here to return to the list of Appendices in the Staff Report. Comment [A10]: It is our protocol to update

ASTM method number s, add titles, and reformat the

references in this manner.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

– PARs 330, 337, 349, & 353 Page C-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 321 321 - 1 September 20, 2010[ date of amended rule adoption ] Appendix C Santa Barbara County Annotated Proposed Amended Rule 321, Solvent Cleaning Machines and Solvent Cleaning

RULE 321. SOLVENT CLEANING MACHINES AND SOLVENT CLEANING. (Adopted 2/24/1975, readopted 10/23/1978, revised 6/11/1979, 7/ 10/1990, 4/17/1997, 7/17/1997, 9/18/1997, and

9/20/2010 , and [ date of amended rule adoption ] )

A. Applicability

This rule shall apply to any person who owns, operates, or uses any solvent cleaning machine or performs any solvent cleaning operation outside of a solvent cleaning machine during the production, repair, maintenance, or servicing of parts, products, tools, ma chinery, equipment, or in general work areas at any stationary source.

B. Exemptions

Except as otherwise specifically provided herein, the provisions of this rule shall not apply to the following:

[. . .]

6. Any equipment or operation that is subject to or specifically exempted by any of the following

District rules.

a. Rule 325, Crude Oil Production and Separation.

b. Rule 326, Storage of Reactive Organic Compound Liquids.

c. Rule 330, Surface Coating of Metal Parts and Products.

d. Rule 337, Surface Coating of Aircraft or Aerospace Vehicle s Parts and Products Components

.

e. Rule 339, Motor Vehicle and Mobile Equipment Coating Operations.

f. Rule 343, Petroleum Storage Tank Degassing.

g. Rule 344, Petroleum Sumps, Pits and Well Cellars.

h. Rule 349, Polyester Resin Operations.

i. Rule 351, Surface Coating of Wood Products.

j. Rule 353, Adhesives and Sealants.

k. Rule 354, Graphic Arts.

Notwithstanding this exemption, the applicable Rule 321 requirements apply if a rule for any above process specifies a solvent cleaning machine shall comply with the applicable provisions of

Rule 321.

[. . .]

Click here to return to the list of Appendices in the Staff Report. Comment [A11]: PARs 330, 337, 349, and 353 include a section indicating Rule 321 provisions apply when using a solvent cleaning machine.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

– PARs 330, 337, 349, & 353 Page D-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 1 January 20, 2000[ date of amended rule adoption ] Appendix D Santa Barbara County Annotated Proposed Amended Rule 330, Surfa ce Coating of Metal Parts and Products

RULE 330. SURFACE COATING OF METAL PARTS AND PRODUCTS. (Adopted 6/11/1979, revised 7/10/1990, 7/24/19 90, 11/13/1990, 4/21/1995, and 1/20/2000 , and [ date of amended rule adoption ] )

A. Applicability

This rule is applicable to any person who manufactures , any metal part coating or metal product coating for use within the District, as well as to any person who uses, applies

, or specifies solicits the use or application

of any metal part coating, metal product surface coating s, or associated solvent within the District for metal parts and products

.

B. Exemptions

1. The provisions of Section D shall not apply to any non-complying coatings with separate formulations used in volumes of less than 20 gallons of each non-complying formulation per stationary source in any calendar year . provided that To qualify for this exemption from Section
D, the total volume of non-complying coatings used at a stationary source does shall not exceed 55 gallons annually. Coatings used for operatio ns that are exempt per Sections B.2, B.3 , and B.4

, B.5, B.10, and B.12 shall not be included in calculating the volume of coatings used under this exemption. Any person claiming this exemption shall maintain on a daily basis records consistent

with Section H.6 and make them available to the District for review upon request

. In addition, such person shall be subject to the records required by Section H.

2. The provisions of Section DE and H shall not apply to touch-up coatings, and repair coatings, and texture coatings, provided Section D limits are met and records are maintained pursuant to a Permit to Operate

.

3. This Rr ule shall not apply to residential non-commercial metal parts and products coating operations.

4. The provisions of tT his Rr ule shall not apply to the surface coating of parts or products and

associated solvent where the only metal involved is fasteners, nails, pins, rivets, hinges, hasps

, and

similar devices used to hold the non-metalnonmetal parts together and which do not constitute a substantive part of the total surface area.

5. The provisions of tT his Rr ule shall not apply to coatings supplied in non-refillable as aerosol products in non-refillable containers having capacities of 18 ounces or less

.

6. The provisions of tT his Rr ule shall not apply to the coating operations listed below

, which are

covered under the categories rules cited.

a. Aircraft or aA erospace vehicle s or component finishing or refinishing (Rule 337 , Surface Coating of Aerospace Vehicles and Components )

, or
,

b. Automobile or truck refinishing (Rule 339 , Motor Vehicle and Mobile Equipment Coating Operations )

, or
,

c. Marine vessel finishing or refinishing (Rule 317 , Organic Solvents )

, or,

d. Stationary structures (Rule 323 , Architectural Coatings ) ., or Comment [A12]: Our practice is to add for use

within the District and uses text to explain and narrow the scope of the rule. Adding and

associated solvent extends the applicability to solvent cleaning. This change stems from a commitment in the 2010 Clean Air Plan (CAP).

Comment [A13]: Our protocol is to specify requirements are on a stationary source basis. By adding per stationary source , misinterpretations that the requirements are on a facility basis should

be avoided. See Rule 102 for definitions of stationary source and facility

.

Comment [A14]: The original exemption is retained in response to industry concerns. Deleting

the “18 ounce or less” text is consistent with the PAR 337.B.3 exemption. The SC and VC m etal coating rules do not include capacities in their “aerosol coating product” exemptions.

Comment [A15]: Including rule titles for

referenced rules follows an EPA recommendation.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-2 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 2 January 20, 2000[ date of amended rule adoption ] e. Application of adhesives and sealants (Rule 353, Adhesives and Sealants).

7. Any coating and associated solvent subject to the requirements of this Rulerule shall be exempt from the requirements of any other coating or solvent rule except Rule s 317 , Organic Solvents,

and Rule 322 , Metal Surface Coating Thinner and Reducer

.

8. This rule shall not apply to any cleaning performed with a solvent (including emulsions) that contains two percent by weight or less of each of the following:

a. Reactive organic compounds, and

b. Toxic air contaminants (as determined by ge neric solvent data, solvent manufacturer’s composition data or by a gas chromatography test and a mass spectrometry test).

c. Any person claiming this exemption shall maintain the records specified in Sections

H.1.a and H.1.f in a manner consistent with Section H.9 and make them available for

review.

9. This rule shall not apply to stripping of cured coatings, cured adhesives, cured sealants, and cured inks, except the stripping of such materials from spray application equipment

.

10. Sections D, E, and J, shall not apply to any of the following:

a. Stencil coatings;

b. Safety-indicating coatings;

c. Magnetic data storage disk coatings;

d. Solid-film lubricants;

e. Electric-insulating and thermal-conducting coatings

.

11. Section J shall not apply to any of the following:

a. Cleaning of semiconductor and micr oelectromechanical devices undergoing manufacturing processes involving thin film deposition, vacuum deposition, dry etching, or metal lift-off operations; including any maintenance activities associated with such operations;

b. Cleaning of metal in electronic components;

c. Cleaning of encasements, including decoy shells or box casings, for electronic components that have a total surface area that is less than 2 square feet;

d. Cleaning of parts, subassemblies, or asse mblies that are exposed to strong oxidizers or reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine);

e. Cleaning of transparencies, polycarbonate, or glass substrates;

f. Cleaning of solar cells, coated optics, la ser hardware, scientific instruments, highprecision optics, telescopes, microscopes, and military fluid systems;

g. Cleaning or stripping of coating overspray from personal protective equipment. Comment [A16]: Essentially the same as the Rule 321.B.1 exemption.

Comment [A17]: Same as the Rule 321.B.4 exemption.

Comment [A18]: Similar to provisions in South Coast AQMD (SC) Rule 1107(f)(1) and San Joaquin Valley Unified APCD (SJV) Rule 4603.4.8.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-3 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 3 January 20, 2000[ date of amended rule adoption ] 12. This rule shall not apply to coatings that contain less than 20 grams of reactive organic compound per liter (0.17 pounds of reactive organic compo und per gallon) of coating, less water and less exempt compounds, as applied.

C. Definitions

See Rule 102 , Definitions, for definitions not limited to this rule. For the purposes of this Rulerule , the following definitions shall apply:

1. “ Aircraft or Aerospace Vehicle or Component ” means a ny fabricated part, processed part, assembly of parts

, or completed unit of any aircraft including but not limited to airplanes , helicopter s
, missile s, rockets, or and space vehicle s includes satellites

.

2. “Air dD ried” means a process whereby the coated object is cured or dried at a temperature less

than 90 °C degrees Celsius (194 °F degrees Fahrenheit ).

“Associated Solvent” means any solvent used in a solvent cleaning machine or for solvent cleaning performed in association with surface coating of any metal part or product.

3. “Baked” means a process whereby the coated obje ct is heated to a temperature of 90 °C degrees

Celsius (194 °F degrees Fahrenheit ) or greater for the purpose of curing or drying.

“Coating” means a material applied onto or impregnated into a substrate for protective, decorative, or functional purposes. Such materials include, but are not limited to, paints, varnishes, sealers, and stains. For the purposes of Rule 330, photoresist co atings are not considered to be coatings.

“Compliant Material” means any coating or solvent that has a reactive organic compound content that complies with the applicable limit in Sections D.1, D.2, D.3, or J.

“Control” means the reduction, by destruction or removal, of the amount of affected pollutants in a gas stream prior to discharge to the atmosphere.

4. “Detailing or Touch

- up Guns” are small air spray equipment, including air brushes, that operate at no greater than 5 cfm cubic feet per minute air flow and no greater than 50 pounds per square inch gauge (psig) air pressure and are used to coat sm all products or portions of products.

“Dip Coat Application” means any process in which a substrate is immersed in a solution (or dispersion) containing the coating material, and then withdrawn.

“Electric -Insulating and Thermal- Conducting Coating” means a coating that displays an electrical insulation of at least 1,000 volts direct current per mil (0.001 of an inch) on a flat test plate and an average thermal conductivity of at least 0.27 British thermal units per hour-foot-degree-Fahrenheit.

“Electric

- Insulating Varnish” means a non-convertible-type coating applied to electric motors, components of electric motors, or power transformers , to provide electrical, mechanical, and environmental protection or resistance.

“Electrodeposition” means the application of a coating using a water-based electrochemical bath process

. The component being coated is immersed in a bath of the coating. An electric potential is applied between the component and an oppositely charged electrode hanging in the bath. The electric potential causes the ionized coating to be electrically attracted, migrated , and deposited on the component being coated.

5. “Electrostatic Application” means using a sufficient charging of atomized paint droplets to cause deposition by electrostatic attraction. This a pplication requires a minimum 60kV power supply. Comment [A19]: The District protocol is to remove degree symbols, abbreviations, and acronyms. Hence, they are spelled out here and

elsewhere.

Comment [A20]: The Section B.10.e exemption

uses the electric-insulating and thermalconducting coating term. The definition is modeled

on the SC Rule 1107 definition.

Comment [A21]: This term coupled with extreme performance coating are replacing industrial maintenance coating . The electricinsulating var nish definition is modeled on the SC

Rule 1107 defin ition.

Comment [A22]: Replaced by the term “electrostatic spray” and relocated it to Rule 102.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-4 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 4 January 20, 2000[ date of amended rule adoption ] 6. “Exempt Organic Compounds” means those compounds listed as exceptions in the definition of

“ Reactive Organic Compounds ” in Rule 102.

“Extreme Performance Coating” means a coating used on a metal surface where the coated surface is, in its intended use, subject to the following:

a. Chronic exposure to corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical mixtures or solutions including water immersion; or

b. Repeated exposure to temperatures in excess of 250 degrees Fahrenheit; or

c. Repeated heavy abrasion, including mech anical wear and repeated scrubbing with industrial grade solvents, cleansers, or scouring agents.

“Flow Coat Application” means any coating application system, with no air supplied to the nozzle, where paint flows over the part and the excess coating drains back into the collection system.

7. “Grams of Reactive Organic Compoun ds per Liter of Coating

, Less Water and Less Exempt Compounds” means the weight of reactive organic compou nds per combined volume of reactive organic compounds and coating solids and can be calculated by the following equation:

Grams of ROCreactive organic compounds W

s - W

w - W

es per liter of coating, less water and less = exempt compounds V

m - V

w - V

es

Where: W

s = Weight of volatile compounds in grams

W

w = Weight of water in grams

W

es = Weight of exempt organic compounds in grams

V

m = Volume of material in liters

V

w = Volume of water in liters

V

es = Volume of exempt organic compounds in liters

8. “Hand Application Method” means the application of a surface coating by manually held nonmechanically operated equipment. Such equipment incl udes paint brush, hand-roller, trowel, spatula, dauber, rag or sponge.

9. “High Volume Low Pressure Spraying” means using spray equipment with air pressure between 0.1 and 10.0 psi and air volume greater than 15.5 cfm per spray gun.

10. “Industrial maintenance coating” means high performance coatings which are formulated for the purpose of heavy abrasion, water immersion, chemical, corrosion, temperature, electrical or

solvent resistance.

“Magnetic Data Storage Disk Coating” means a coating used on a metal disk which stores data magnetically.

11. “Metal Part or Product” means any part, assembly of parts or completed unit fabricated in part

or in total from metal.

“Non

- Complying Coating” means a coating with a reactive or ganic compound content above a limit specified in Section D.1, 2, or 3.

“Non

- Powder Coating” means any coating that is not a powder coating.

“Noncompliant Material” means any coating or solvent that has a reactive organic compound content that does not comply with the applicable limit in Sections D.1, D.2, D.3, or J. Comment [A23]: The District has replaced exempt organic compound with exempt compound in Rule 330. Also, we are adding exempt compound to Rule 102, Defin itions.

Comment [A24]: Added “including water immersion” per Industry request at the August 10, 2011 workshop.

Comment [A25]: The definition is modeled on

the SC Rule 1107 defin ition. This term coupled with

electric -insulating varnish are replacing industrial maintenance coating

.

Comment [A26]: Replaced by the term “high volume low pressure spraying equipment” and

relocated it to Rule 102.

Comment [A27]: Rule 323, Arch itectural Coatings, uses the i ndustrial maintenance coatings

term and ARB recommends it be deleted from Rule

330. Extreme performance coating and electricinsulating varnish are used in its place.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-5 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 5 January 20, 2000[ date of amended rule adoption ] “ Powder Coating ” means any coating applied as fine particle solids with less than 4 percent by weight reactive organic compound or other liquid carriers.

12. “Repair Coating ” means a coating used to re

- coat ing portions of a previously coated product due

to which has sustained mechanical damage to the coating following normal painting coating operations.

“Safety

- Indicating Coating” means a coating which changes physical characteristics, such as color, to

indicate unsafe conditions.

“Solid

- Film Lubricant” means a very thin coating consisting of a binder system containing as its chief pigment material one or more of molybdenum disulfide, graphite, polytetrafluoroethylene (PTFE), or other solids that act as a dry lubricant between faying surfaces

.

“Solvent” means any liquid containing any reactive organic compound or any toxic air contaminant, which is used as a diluent, thinner, dissolver, viscosity redu cer, cleaning agent, drying agent, preservative, or other

similar uses.

“Solvent Cleaning” means any activity, operation, or process (including, but not limited to, surface preparation, cleanup, or wipe cleaning) performed outs ide of a solvent cleaning machine, that uses solvent to remove uncured adhesives, uncured coatings, uncu red inks, uncured polyester resin material, uncured sealant, or other contaminants, including, but not limite d to, dirt, soil, oil, lubricants, coolants, moisture, fingerprints, and grease, from parts, products, tools, machinery, application equipment, and general work areas. Cleaning spray equipment used for the application of coating, adhesive, ink, polyester resin material,

or sealant is also considered to be solvent cleani ng irrespective of the spray material being cured.

“Solvent Cleaning Machine” means any device or piece of equipment that uses solvent liquid or vapor to remove soils, moisture, or other contaminants from th e surfaces of materials. Types of solvent cleaning machines include, but are not limit ed to, batch cold, batch vapor, in-l ine cold, in-line vapor, remote reservoir, and gas-path solvent cleaners. Buckets, p ails, and beakers with capacities of 3.785 liters (1.00 gallon) or less are not considered solvent cleaning ma chines. However, the use of such a container or similar containers (e.g., hand-held spray bottles) wi th a liquid solvent for cleaning is considered to be solvent cleaning. Any device or piece of equipment used exclusively for stripping shall not be considered to be a solvent cleaning machine.

“Stencil Coating” means an ink or a coating which is rolled or brushed onto a template or stamp in order to add identifying letters and/or numbers to metal parts and products.

“Te xture Coating ” means any coating that is applied to a metal pa rt or product which, in its finished form,

consists of discrete rais ed spots of the coating.

13. “Touch

- uU p Coating ” means that portion of the coating operation which is separate from the a coating used to cover minor coating imperfections appearing after the main coating operationprocess but necessary to cover minor imperfections or to achieve coverage as required

.

14. “Transfer efficiency” means the ratio of the weight of coating solids adhering to the object being coated to the weight of coating solids used in th e application process, expressed as a percentage.

D. Requirements

- – Reactive Organic Compound s Limits

A No person shall not apply any coating or specify solicit the use of any coating on any metal part or product subject to the provisions of this Rulerule, which, as applied, emits or may emit contains reactive organic compounds into the atmosphere in excess of the following limits . These limits are expressed in

grams of reactive organic compound per liter or pounds of reactive organic compound per gallon of coating

, less water and less exempt organic compounds. Comment [A28]: Section B.10 uses the safetyindicating coating and solid-film lubricant terms.

Comment [A29]: Solvent, solvent cleaning, and solvent cleaning machine are the same definitions

found in Rule 321. Solvent includes any liquid containing any toxic air contaminant.

Comment [A30]: Section B.10 uses this term.

Comment [A31]: This term has been relocated to

Rule 102.

Comment [A32]: Our practice is to improve text flow by changing the sentence structure in this

manner.

Comment [A33]: ARB suggested the text changes in a letter dated February 2, 1995.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-6 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 6 January 20, 2000[ date of amended rule adoption ] 1. Non-Powder Coatings except Air Dried Industrial Maintenance Extreme Performance Coatings and Air Dried Electric-Insulating Varnish :

Air Dried Baked

340 grams per liter 275 grams per liter 2.8 pounds per gallon 2.3 pounds per gallon

2. Non-Powder Industrial Maintenance Extreme Performance Coatings and Electric-Insulating

Varnish - 420 grams per liter, 3.51 pounds per gallon (when air dried)

3. Powder Coatings - 50 grams per liter, 0.42 pound per gallon

4. Sources A person may elect to use an add-on exhaust control system equipment to achieve as an alternative to meeting the requirements compliance with provisions of Section s D .1, D.2, D.3, E,

and J , provided that the control equipment meets all of the applicable requirements of Sections a

and b below are met

. Such control equipment must be ap proved in advance by the Control

Officer. Any person choosing to install such control equipment system shall obtain an Authority to Construct from the District prior to installation.

a. The control device shall reduce emissions from an emission collection system by at least 95 percent by weight.

b. The emission collection system which collects and transports emissions to an air pollution control device shall collect at least 90 percent by weight of the emissions generated by the sources of emissions.

a. The overall efficiency (the capture efficiency multiplied by the control device efficiency) of the total system shall be at least 85.5 percent, by weight. Alternatively, the control device reactive organic compound exhaust concentration shall not exceed 10 parts per million by volume as propane or other limit approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer.

b. Combustion temperature shall be continuously monitored when operating a thermal

incinerator.

c. Inlet and exhaust gas temperatures shall be continuously monitored when operating a catalytic incinerator.

d. Control device efficiency shall be continuously monitored when operating a carbon

adsorber or a control device other than a thermal or catalytic incinerator.

e. Compliance through the use of an add-on control system shall not result in affected pollutant emissions in excess of the affected pollutant emissions that would result from compliance with Sections D.1, D.2, D.3, E, and J.

E. Requirements

- – Application Equipment

ANo person shall not apply coatings subject to the provisions of this rule except by using properly operated unless the application is performed with equipment and by operating according to the manufacturers operating guidelines. In addition, except as provided in Section D.4, the application method employed shall be one of the following :

1. Electrostatic spray application, or

2. Flow coat application, or Comment [A34]: Including pounds per gallon equivalents is an approach used in Rule 337.

Comment [A35]: Deleting industrial maintenance coating and replacement it with extreme performance coatings and electricinsulating varnish follows an ARB

recommendation.

Comment [A36]: Following other air district methods, sources may comply with the S ection E(application equipment) and Section J (solvent ROCcontent) provisions by using an add -on control
system.

Comment [A37]: Similar to the Rule 321.N.1 provision.

Comment [A38]: Subsections b - d mirror Rule 353.I provisions.

Comment [A39]: Similar to Rule 321.N.6. ( Reactive organic compound changed to affected pollutant to include TACs.)

Comment [A40]: ARB suggested the addition of according to the manufacturers operating guidelines.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-7 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 7 January 20, 2000[ date of amended rule adoption ] 3. Dip coat application, or

4. High volume

, low pressure spraying equipment , or

5. Electrodeposition, or

6. Hand application methods, or

7. Detailing or touch-up guns, or

8. Any other coating application method that is demonstrated to the satisfaction of approved by the Control Officer, the Air Resources Board, and the Environmental Protection Agency, achieves that has a coating transfer efficiency at leas t equivalent to or greater than 65 percent transfer efficiency

as demonstrated by measured using the test method specified in Section I.4.

F. Requirements

- – Closed ContainersGeneral Operating

Any person who owns, operates, or uses any application equipment to surface coat any metal part or product shall meet the following requirements:

1. All reactive organic compounds-containing materials, used or unused, including

, but not limited

to

, surface coatings, thinners, cleanup solvents, or surface preparation materials shall be stored and disposed of in closed nonabsorbent and nonleaking containers equipped with tight-fitting covers

. All covers shall be in place unless adding material to or removing material from the containers

, and opened only during extraction or introdu ction of material for mixing, use or storage the containers are empty, or doing maintenance/inspection of the containers

.

2. All application equipment, ventilation system, an d emission control equipm ent shall be installed, operated, and maintained consistent with the manufacturer’s specifications.

3. Waste solvent, waste solvent residues, and any other waste material that contains reactive organic compounds shall be disposed of by one of the following methods:

a. A commercial waste solvent reclamation service licensed by the State of California.

b. At a facility that is federally or state license d to treat, store or dispose of such waste.

c. Recycling in conformance with Section 25143.2 of the California Health and Safety

Code.

4. All covers, valves, drain plugs, and other closur e devices designed to reduce surface coating or solvent evaporation shall not be removed or opened except to process work or to perform monitoring, inspections, maintenance, or repairs th at require the removal of the covers or other

closure devices.

5. Any surface coating or solvent spills shall be wiped up immediately and the used absorbent material (e.g., cloth, paper, sand, sawdust, etc. ) shall be stored in closed containers that are

handled in accordance with Section F.1.

6. The handling and transfer of coatings and cleani ng solvents to or from enclosed systems, vats, waste containers, and other cleaning operation equipm ent that hold or store fresh or spent coatings and cleaning solvents shall be conducted in such a manner to minimize spills. Comment [A41]: The housekeeping provisions are similar to requirements found in Rule 321.D.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-8 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 8 January 20, 2000[ date of amended rule adoption ] 7. Containers used to store coating, solvent, or any waste material that contains reactive organic compounds subject to this rule shall be marked or clearly labeled indicating the name of the material they contain.

G. Requirements

- – Manufacturer Labeling

1. Each container of any coating subject to this rule shall display the date on which the contents were manufactured or a code indicating the date of manufacture. Each manufacturer of such coatings

shall file with the Control Officer and the Executive Officer of the California Air Resources Board, an explanation of each code.

2. Each container of any coating subject to this rule shall display a statement of the manufacturer's recommendation regarding thinning of the coating. This recommendation shall not apply to the thinning of coatings with water. The recomme ndation shall specify that the coating is to be employed without thinning or diluting under normal environmental and application conditions unless any thinning recommended on the label for normal environmental and application conditions does not cause a coating to exceed its applicable standard for reactive organic compound content.

3. Each container of any coating subject to this rule shall display the maximum reactive organic compound content of the coating, as applied, an d after any thinning as recommended by the manufacturer. Reactive organic compound content shall be displayed as grams of reactive organic compounds per liter or pounds of reactive organic compound per gallon of coating

, less water and

less exempt solventscompounds . The volatile organic compound content may be displayed instead of the reactive organic compound content as long as the manufacturer's definition of volatile organic compound is consistent with the definition of reactive organic compound

contained in District Rule 102 , Definitions . Reactive organic compound content displayed may be calculated using product formulation data and the formula in Section C , or may be determined using the test method in Section HI.1

.

H. Requirements

- – Recordkeeping

Any Persons person subject to this Rulerule shall comply with the following requirements. Any owner or operator of any stationary source comprised of more than one facility may comply with the following requirements on a facility basis.

1. Maintain a current listingfile of all reactive organic compound

- containing materials in use at the stationary source subject to this Rulerule. The file shall provide all of the data necessary to evaluate compliance and shall include the following information, as applicable:

a. material name and manufacturer identification (e.g., brand name, stock identification number) ;

b. application method;

c. material type ( i.e. e.g., air dried or baked enamel, powder coating, industrial maintenance extreme performance coating, cleanup solvent, etc.) , type operation (e.g., coating, stripping, or solvent cleaning), and, for non-powder coating operations, the drying method and equipment coated ;

d. specific mixing ratiodata (e.g., component volumes or weights) of each component for

each batch sufficient to determine the mixture’s reactive organic compound content ;

e. the corresponding reactive or ganic compound content limit from Sections D.1, D.2, D.3

and J.1 and the maximum actual as - applied reactive organic compound content of each Comment [A42]: Adding for reactive organic compound content follows an ARB

recommendation.

Comment [A43]: Inserting and the formula in

Section C follows an ARB suggestion relative to Rule 337 ( letter dated February 2, 1995).

Comment [A44]: Our protocol is to specify requirements are on a stationary source basis. By adding in use at the stationary source

, misinterpretations that the requirements are on a facility basis should be avoided.

Comment [A45]: Essentially the same text found

in Rule 353.O.1.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-9 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 9 January 20, 2000[ date of amended rule adoption ] the material s used, less water and less exempt compounds (including thinning solvents) ; and

f. current coating and solvent manufacturer specification sheets, Material Safety Data Sheets, product data sheets, or air quality data sheets, which list the reactive organic compound content of each material in use at the stationary source subject to this rule. Compliance with this provision may be done by ensuring the manufacturer’s specifications are listed on the product container.

2. For each industrial maintenance coating, a list of each part or product coated on a monthly basis.[Reserved]

3. Current coating manufacturer specification sheets , Material Safety Data Sheets or current air quality data sheets, which list the reactive organic compounds content of each material in use at their facility, shall be available for review on site.

43 . Maintain purchase records identifying the type or name and the volume of material purchased for each reactive organic compound s -containing material . purchased for use at the stationary source. The records shall include, but not be limited to, the following:

a. material name and manufacturer identification (e.g., brand name, stock identification number); and

b. material type (e.g., air dried or baked enamel, powder coating, extreme performance coating, cleanup solvent, etc.).

4. Maintain records of the disposal method each time waste solvent, waste solvent residue, or other waste material that contain reactive organic compounds is removed from the stationary source for disposal.

5. Maintain For each material maintained in response to Section H.1.a, maintain, at a minimum, on a monthly basis for compliant material and on a daily basis for noncompliant material, a record of

the following:

a. volume used (gallons per day, gallons per month);

b. reactive organic compound s content (grams per liter or pounds per gallon); and

c. and resulting reactive organic compound emissions (pounds per day, pounds per month)of each reactive organic compounds-containing material used

.

For permitted facilities and users of non-complian t coatings, all records required by Section H.1 shall be summarized for each calendar year and su bmitted to the District by March 1 of the following year.

6. Operators of facilities that use non-compliant coating materials that do not achieve compliance through the operation of emission control equipm ent shall maintain daily records of the volumes of non-compliant coating materials used. In addition, operators claiming the Section B.1 exemption shall maintainAny person claiming an exemption under the Section B.1 shall maintain :

a. Daily records of the volumes in gallons of non- compliantcomplying coating materials used by each separate formulation at the stationary source

.

b. Annual running totals, from January 1 of each calendar year, of the volume in gallons of

non- compliant complying coating materials used at the stationary source for: Comment [A46]: Information on the coating categories and equipment coated is now required via 330.H.1.c. Thus, this Section is now reserved

.

Comment [A47]: Moved to 330.H.1.f.

Comment [A48]: The daily recordkeeping provision was added for consistency with the EPA “Guidance Document for Correcting Common VOC

& Other Rul e Deficiencies.”

Comment [A49]: Moved the annual reporting requirements to Section L per industry suggestion.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-10 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 10 January 20, 2000[ date of amended rule adoption ] 1) Each separate formulation.

2) All formulations.

7. Operators of facilities For any stationary source that use s non-compliant coating materials with compliance achieved through the operation of emission control equipment as an alternative to meeting the requirements of Sections D.1, D.2, D.3, E, or J, shall maintain daily records of key operating parameter values and maintenance procedures which that demonstrate continuous operation and compliance of the emission control device system during periods of emission producing activities shall be maintained

. These parameters shall include, but not be limited to:

a. Hours of operation;

b. All maintenance work that requires the emission control system to be shut down; and

c. All information needed to demonstrate continuous compliance with Section D.4, such as temperatures, pressures, and/or flow rates.

8. Any records required by to be maintained pursuant to this rule shall be kept on site for at least 2 years unless a longer retention period is otherwise required by state or federal regulation(s). Such records shall be readily available fo r shall be retained and available for inspection by the Control Officer or designated repr esentative upon request for the previo us 36-month periodand review by

the District

.

I. Requirements

- – Compliance Provisions and Test Methods

1. Coating s and solvent reactive organic compound content shall be determined measured using by

the Environmental Protection Agency Reference Method 24 , or its constituent methods , or an equivalent method approved by the Environmental Protection Agency, the Air Resources Board,

and the Control Officer

. The determination of exempt compounds shall be performed in accordance with ASTM D 4457-1991, “ Standard Test Method for Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings by Direct Injection into a Gas Chromatograph, ” ASTM International. Alternatively, determination of exempt compounds may be performed in accordance with the South Coast Air Quality Management District Method 303- 91, “Determination of Exempt Compounds,” August 1996. The reactive organic compound content of materials containing 50 grams of reactive organic compound per liter or less shall be determined by the South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board,

and the Control Officer.

2. Compliance with Section D.4.a The control device efficiency for reactive organic compound

emissions shall be determined by using Air Resources Board Method 100 or Environmental Protection Agency Methods 18, 25 , or 25A , the South Coast Air Quality Management District Method 25.1, “ Determination of Total Gaseous Non- Methane Organic Emissions as Carbon,” February 1991, or the South Coast Air Quality Management District Method 25.3, “ Determination of Low Concentration Non-Methane Non-Ethane Organic Compound Emissions from Clean Fueled Combustion Sources,” March 2000, as applicable. Environmental Protection Agency Test Method 18 or Air Resources Board Method 422, “ Exempt Halogenated VOCs in Gases ,” September 12, 1990, shall be used to determine emissions of exempt compounds

. Comment [A50]: Subsections a - c are from Rule

321.R.1.c.

Comment [A51]: EPA recommended referring to

SC Method 313 for d etermining ROC content of materials containing < 50 g/l.

Comment [A52]: EPA recommended that this provision mirror the SC Rule 1122(h)(7)(B) text.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-11 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 11 January 20, 2000[ date of amended rule adoption ] 3. Compliance with Section D.4.b The capture efficiency for reactive organic compound emissions

shall be determined according to by verifying the use of a Permanent Total Enclosure and 100 percent capture efficiency as defined by Environmental Protection Agency Method 204 and 204AF., “ Criteria for and Verification of a Permanent or Temporary Total Enclosure.” Alternatively, if an Environmental Protection Agency Method 204 defined Permanent Total Enclosure is not employed, capture efficiency shall be determined using a minimum of three sampling runs subject to data quality criteria presented in the Environmental Protection Agency technical guidance

document “ Guidelines for D etermining Capture Efficiency, January 9, 1995.” Individual capture efficiency test runs subject to the Environmental Protection Agency technical guidelines shall be determined by:

a. The Temporary Total Enclosure approach of Environmental Protection Agency Methods

204 thro ugh 204F; or

b. The South Coast Air Quality Management District “ Protocol for Determination of Volatile Organic Compounds (VOC) Capture Efficiency, ” May 1995.

4. Compliance with Section E.8 Application equipment coating transfer efficiencies shall be

determined measured using South Coast Air Quality Management District Method “ Spray Equipment Transfer Efficiency Test Procedure offor Equipment User, ” May 24, 1989.

5. The control device efficiency for toxic air cont aminant emissions that are not reactive organic compounds shall be determined using:

a. an Environmental Protection Agency approved test method or methods, or

b. in the case where there is no Environmental Protection Agency approved test method, a District approved detection method applicable for each target toxics specie.

c. the Control Officer may require more than one test method on any emission control device where necessary to demonstrate that the overall efficiency is at least 85.5 percent by weight in reducing emissions of reac tive organic compounds and/or toxic air contaminants. Any technique to convert “parts per million by volume” test method results to either 1) “parts per million by weight,” or 2) “mass emission rates” (e.g., pounds per hour) shall first be approved by th e Control Officer and, if such approval is not provided, then the technique shall not be used to show compliance with this rule.

6. The capture efficiency for toxic air contam inant emissions that are not reactive organic compounds shall be determined by using the me thods described in Section I.3 modified in a manner approved by the District to quantify the mass of liquid or gaseous reactive organic compounds and/or toxic air contaminants.

7. Emissions of reactive organic compounds from th e exhaust of an emission control system shall be measured by the Environmental Protection Agency Method 25, in combination with Environmental Protection Agency Method 18 or the California Air Resources Board Method 422, “Exempt Halogenated VOCs in Gases,” Se ptember 12, 1990 (to determine emissions of exempt compounds).

8. When more than one test method or set of test methods are specified for any testing, a test result showing an exceedance of any limit of this rule shall constitute a rule violation.

9. The Environmental Protection Agency test methods in effect on [ date of amended rule adoption ] shall be the test methods used to meet the requirements of this rule. Comment [A53]: EPA recommended that the District model the provisions on SC Rule 1122(h)(7)(A) text.

Comment [A54]: Essentially the same as Rule 321.P.4 provisions.

Comment [A55]: Similar to the Rule 321.P.3 requirements.

Comment [A56]: Added per the EPA recommendation in the Technical Support Document for SJV Rule 4605 (June 2009).STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-12 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 12 January 20, 2000[ date of amended rule adoption ] J. Requirements

– Solvent Cleaning Associated with Surfac e Coating of Metal Parts and Products

Section J requirements shall apply to any person performing solvent cleaning associated with surface coating of metal parts and products, including, but no t limited to, use of wipe cleaning cloths, hand-held spray bottles, squirt bottles, aeroso l products, and the cleaning of application equipment. The following requirements become effective [ one year from the date of amended rule adoption ] and are in addition to the general operating requirements specified in Section F.

1. Solvent Requirements

Except when using an emission control system that meets the requirements of Section D.4, no person shall use any solvent to perform solvent cleaning which exceeds the applicable grams of reactive organic compound per liter of material limit specified in Table 330-1.

Table 330-1: Reactive Organic Compound Content Limits for Solvent Cleaning Associated with Surface Coating of Metal Parts and Products

SOLVENT CLEANING ACTIVITY ROC Limit, grams of ROC per liter of

material (pounds of ROC per gallon of material)

(a) Metal Parts and Products Surface Preparation for Coating Application 25 (0.21)

(b) Cleaning of Coatings Application Equipment 25 (0.21)

K. Compliance Schedule

Any person who owns, operates, or uses any application equipment to surface coat any metal part or product shall meet the following compliance schedule:

1. By [ 30 days from the date of amended rule adoption ], comply with Section F, Requirements - General Operating.

2. By [ six months from the date of amended rule adoption ], comply with the recordkeeping provisions in the following Sections:

a. H.1.d - mixing data,

b. H.1.e - reactive organic compound content data,

c. H.3 - purchase records,

d. H.4 - waste disposal records, and

e. H.5 - daily records for noncompliant materials.

3. By [ one year from the date of amended rule adoption ], comply with the Section J and Section M requirements.

4. By [ date of amended rule adoption ], comply with all other provisions of this rule. Comment [A57]: Section J stems from similar solvent cleaning provisions in Rule 321.M.

Comment [A58]: Both ARB and EPA recommend a 25 g/l limit on the solvent's ROC

content.

Comment [A59]: The compliance schedule provision was expanded in response to a request from Industry.STAFF REPORT

– PARs 330, 337, 349, & 353 Page D-13 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 330 330 - 13 January 20, 2000[ date of amended rule adoption ] L. Reporting Requirements

Submittal of an annual report to the District is required if:

• A person holds a permit for equipment subj ect to the requirements of this rule, or

• A person is subject to the requirements of th is rule and applies non-complying coatings.

The annual report shall be submitted to the District by March 1 and it shall contain the following information for the previous calendar year:

1. monthly totals (gallons) of co mpliant and noncompliant material used based on the records required by Section H.5,

2. annual totals (gallons) bas ed on each of the coating’s and solvent’s monthly data,

3. if claiming the Rule 330.B.1 exemption, annual totals (gallons) of non-complying coatings for each separate formulation and all formulations, per Section H.6.b, and

4. if permitted, name and address of the company or agency, and the Permit to Operate number that the surface coating equipment is subject to.

M. Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solvent cleaning machine shall comply with the applicable provisions of Rule 321, Solvent Cleaning Machines and Solvent Cleaning.

Click here to return to the list of Appendices in the Staff Report. Comment [A60]: The annual report provision

was relocated from Section H.5 to a stand -alone section per an Industry suggestion.

Comment [A61]: Added to clarify that Rule 321 provisions apply to solvent cleaning machines when used in conjunction with surface coating of metal parts and products.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

– PARs 330, 337, 349, & 353 Page E-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 1 October 20, 1994[ date of amended rule adoption ] Appendix E Santa Barbara County Annotated Proposed Amended Rule 337, Surface Coat ing of Aerospace Vehicles and Components

RULE 337. SURFACE COATING OF AIRCRAFT OR AEROSPACE VEHICLE S PARTS AND

PRODUCTSCOMPONENTS . (Adopted 7/10/1990, revised 7/24/1990 , and 10/20/1994 , and [ date of amended rule adoption ] )

A. Applicability

This rule is applicable to any person who manufactures , any aerospace vehicle coating or aerospace component coating for use within the District, as well as any person who uses, applies

, or specifies solicits

the use or application of any aerospace vehicle or component surface coating s or associated solvent within the Districtfor aircraft or aerospace vehicle parts and products

. Rule 337 does not apply to electronic

components.

B. Exemptions

1. The provisions of Section D .1 shall not apply to any non-complying coatings with separate formulations used in volumes of less than 20 gallons of each non-complying formulation per stationary source in any calendar year . provided that To qualify for this exemption from Section D.1, the total volume of non-complying coatings used at a stationary source does not exceed 200 gallons annually. Coatings used for operations that are exempt per Sections B.2 , and B.3 , B.6, B.8, B.11, B.12, and B.13 shall not be included in calculating the volume of coatings used under this exemption. Any person claiming this exemption shall maintain on a monthly daily basis an annual running total of the volume of each separate formulation of coating used under this exemption records consistent with Section H.7 and make them available to the District for review

upon request

. These coatings shall be subject to the records required by Section H.

2. The provisions of Section E . and H shall not apply to touch-up and repair , provided Section D.1 limits are met and records are maintained pursuant to a Permit to Operate

.

3. T he provisions of t his rule shall not apply to coatings (including adhesive products and sealant products) supplied in non-refillable as aerosol products in non-refillable containers with capacities

of 18 ounces or less

.

4. Any coating and associated solvent subject to the requirements of this rule shall be exempt from the requirements of Rule 317 , Organic Solvents, and Rule 322 , Metal Surface Coating Thinner and

Reducer . Any coating exempt from this rule shall comply with all other applicable District Rules.

5. This rule shall not apply to any cleaning performed with a solvent (including emulsions) that contains two percent by weight or less of each of the following:

a. Reactive organic compounds, and

b. Toxic air contaminants (as determined by ge neric solvent data, solvent manufacturer’s composition data or by a gas chromatography test and a mass spectrometry test).

c. Any person claiming this exemption shall maintain the records specified in Sections

H.1.a and H.1.f in a manner consistent with Section H.9 and make them available for

review. Comment [A62]: Under the proposed amended definitions, aircraft is synonymous with aerospace vehicle

.

Comment [A63]: Our practice is to add for use

within the District and uses text to explain and

narr ow the scope of the rule. Adding or associated

solvent extends the applicability to solvent cleaning. This change stems from a commitment in the 2010

Clean Air Plan.

Comment [A64]: The last sentence is added for ease of understanding that surf ace coating of

electronic components is not subject to Rule 337.

This applicability approach follows the EPA guideline (EPA -453/R-97-004) for this source category. Rule 321 governs the cleaning of electronic components.

Comment [A65]: Our protocol is to specify requirements are on a stationary source basis. By adding per stationary source , misinterpretations that the requirements are on a facility basis should

be avoided.

Comment [A66]: EPA recommends daily recordkeeping when using noncompliant coatings. (Ref. EPA’s Rule 337 Techn ical Support Document dated Sept. 20, 1995.)

Comment [A67]: Exempting aerosol coatings is consistent with the 1997 CTG for coating oper ations at aerospace manufacturing and rework operations.

SC Rule 1124(l)(5) and VC Rule 74.13.E.6 ,also have a similar exemption.

Comment [A68]: Including rule titles for

referenced rules follows an EPA recommendation.

Comment [A69]: Essentially the same as the Rule 321.B.1 exemption.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-2 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 2 October 20, 1994[ date of amended rule adoption ] 6. This rule shall not apply to coatings that contain le ss than 20 grams of reactive organic compound per liter (0.17 pounds of reactive organic compound per gallon) of coating, less water and less exempt compounds, as applied.

7. Section D.2 and J.1.a shall not apply to solvents and strippers used in space vehicle manufacturing

and rework.

8. This rule shall not apply to chemical milling an d electrodeposition (except for electrodeposition of coatings).

9. Section J.1.a shall not apply to any of the following:

a. Cleaning of encasements, including decoy shells or box casings, for electronic components that have a total surface area that is less than 2 square feet;

b. Cleaning of parts, subassemblies, or asse mblies that are exposed to strong oxidizers or reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine);

c. Cleaning of aircraft transparen cies, polycarbonate, or glass substrates;

d. Cleaning of solar cells, co ated optics, laser hardware, scientific instruments, highprecision optics, telescopes, microscopes, avio nic equipment, military fluid systems, and thermal control surfaces;

e. Wipe cleaning during the manufacture, asse mbly, installation, maintenance, or testing of components of breathing oxygen systems th at are exposed to the breathing oxygen;

f. Wipe cleaning and surface activation prior to adhesive bonding;

g. Wipe cleaning of aircraft and ground suppor t equipment fluid systems that are exposed to the fluid, including air-to-air heat exchangers and hydraulic fluid systems;

h. Wipe cleaning of fuel cells, fuel tanks, and confined spaces

.

10. Section E shall not apply to any of the following:

a. Any situation that normally requires the use of an airbrush or an extension on the spray gun to properly reach limited access spaces;

b. The use of airbrush application methods for stenciling, lettering, and other identification markings.

11. The chemical milling maskant limits in Section D.1, Table 337-1, shall not apply to any of the following:

a. Touch-up of scratched surfaces or damaged maskant;

b. Touch-up of trimmed edges.

12. Section D.1 shall not apply to electric- and radiation -effect coatings that have been designated as “classified” by the United States Department of Defense.

13. This rule shall not apply to coatings (including ad hesive products and sealant products) subject to the Air Resources Board consumer products regulation found in Title 17 of the California Code of Regulations, section 94507 et seq. Comment [A70]: Exempting low ROC paints is

similar to the SC Rule 1124(l)(13) exemption. Exempting low ROC adhesives and sealants is

consistent with PAR 353.B.7.

Comment [A71]: Modeled on the SC Rule 1124(l)(4) exemption.

Comment [A72]: Based on the 40 CFR Section 63.741(f) exemption.

Comment [A73]: Similar to the Ventura C ounty APCD (VC) Rule 74.13.C.3 exemption.

Comment [A74]: Stems from the 40 CFR

Section 63. 744(e)(10) exemption.

Comment [A75]: 337.B.9.e - h are modeled on exemptions found in 40 CFR Section 63.744(e).

Comment [A76]: Similar to the SC Rule 1124(l)(14) exemption.

Comment [A77]: Modeled on the SC 1124(l)(11) provision.

Comment [A78]: Follows 40 CFR Section 63.747(c)(3)(i) and (ii) exemptions.

Comment [A79]: Stems from 40 CFR 63, Subpart GG, Appendix A’s definition of electric or radiation-effect coating

.

Comment [A80]: Modeled on the South Coast AQMD (SC) Rule 1124(l)(15) and 1168(j)(13) exemptions. This exemption is needed for consistency with the Rule 353.B.12 exemption.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-3 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 3 October 20, 1994[ date of amended rule adoption ] 14. Sections D.2 and J.1.a shall not apply to any of the following:

a. Cleaning or stripping of coating oversp ray from personal protective equipment;

b. Wipe cleaning or stripping during fabrication, assembly, installation, and maintenance of upholstery, curtains, carpet, and other textile ma terials used in the interior of the aircraft;

c. Wipe cleaning or stripping of metallic and nonmetallic materials used in honeycomb cores during the manufacture or maintenanc e of these cores, and cleaning of the completed cores used in the manufacture of aerospace vehicles or components.

C. Definitions

See Rule 102 , Definitions, for definitions not restricted to interpretation of limited to this rule. Definitions specific to this rule are listed belo w. For purposes of this rule, th e following definitions shall apply:

“Ablative Coating” means any 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 as an insulative barrier, protecting adjacent components from the heat or open flame.

“Adhesion Promoter” means any very thin coating applied to a substrate to promote wetting and form a chemical bond with the subsequently applied material.

“Adhesive” means any substance that is used to bond one su rface to another surface by attachment or fused union. Adhesives are a type of specialty coating.

1. “Adhesive Bonding Primer” means a ny coating primer applied in a very thin film to aircraft or

aerospace parts or products components for the primary purpose of providing a primer for a subsequent

coat of structural adhesive corrosion inhibition and increased adhesive bond strength by attachment

.

“Adhesive Product” means any adhesive, glue, cement, mastic, adhesive bonding primer, adhesive primer, adhesive primer for plastics, and any other adhesive primer. Adhesive products are a type of coating.

“Aerospace Vehicle or Component” means any fabricated part, processed part, assembly of parts, or completed unit, with the exception of electronic components, of any aircraft including but not limited to airplanes, helicopters, missiles, rockets, an d space vehicles includes satellites.

2. “Aircraft or Aerospace Vehicle” means a fabricated part, assembly of parts or completed unit of any aircraft, helicopter, missile or space vehicle.

“Aircraft Fluid Systems” mean those systems that handle hydraulic fluids, fuel, cooling fluids, or oils.

“Aircraft Transparency” means the aircraft windshield, canopy, passenger windows, lenses and other components which are constructed of transparent materials.

“Airless Spray” means a spray method in which a pump forces the adhesive through an atomizing nozzle at high pressure (1,000 to 6,000 pounds per square inch).

“Antichafe Coating” means any coating applied to areas of moving aerospace components that may rub during normal operations or installation.

“Associated Solvent” means any solvent used in a solvent cle aning machine or for solvent cleaning performed in association with surface coating of any aerospace vehicle or aerospace component.

“Barrier Coating” means any coating applied in a thin film to fasteners to inhibit dissimilar metal corrosion and to prevent galling. Comment [A81]: Our protocol is to change the

lead-in sentences in this manner.

Comment [A82]: Most of the proposed new definitions are from 40 CFR 63, Subpart GG or the EPA Control Techniques Guideline (CTG) for this source category (EPA-453/R-97-004, Dec. 1997).

Comment [A83]: Same as the Rule 353

“Adhesive” definition.

Comment [A84]: Added for ease of understanding the relat ionship between adhesive and specialty coating

.

Comment [A85]: The term is replaced by aerospace vehicle or components

.

Comment [A86]: The term is used in Section

E.11.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-4 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 4 October 20, 1994[ date of amended rule adoption ] “Bearing Coating” means any coating applied to an antifriction bearing, a bearing housing, or the area adjacent to such a bearing in orde r to facilitate bearing function or to protect base material from excessive wear. A material shall not be classified as a bearing co ating if it can also be classified as a dry lubricative

material or a solid film lubricant.

“Bonding Maskant” means any temporary coating used to protect selected areas of aerospace parts from strong acid or alkaline solutions during processing for bonding.

“Caulking and Smoothing Compounds” mean semi-solid materials which are applied by hand application methods and are used to aerodynamically smoot h 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.

“Chemical Agent

- Resistant Coating” means any exterior topcoat designed to withstand exposure to chemical warfare agents or the decontaminants used on these agents.

“Chemical Milling Maskant” means any coating that is applied directly to aluminum components to protect surface areas when chemical milling the componen t with a Type I or Type II etchant. Type I chemical milling maskants are used with a Type I etch ant and Type II chemical milling maskants are used with a Type II etchant. This definition does no t include bonding maskants, critical use and line sealer 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 maskan ts (i.e., bonding, critical use and line sealer, and seal coat) are not included. Maskants that are defined as specialty coatings are not included under this definition. Section C provides definitions of Type I and Type II etchants.

“Cleaning Operation” means collectively spray-gun, hand-wipe, and flush cleaning operations.

“Cleaning Solvent” means any liquid material used for hand-wipe, spray gun, or flush cleaning. This definition does not include any solution that contains no reactive organic compounds and no toxic air

contaminants.

“Clear Coating” means a transparent coating usually applied over a colored opaque coating, metallic substrate, or placard to give improved gloss and protecti on to the color coat. In some cases, a clear coat refers to any transparent coatin g without regard to substrate.

“Coating” means any 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. Adhesives, sealants, and lubricative material are types of specialty coatings.

“Commercial Exterior Aerodynamic Structure Primer” means any primer used on aerodynamic components and structures that protrude from the fuse lage, such as wings and attached components, control surfaces, horizontal stabilizers, vertical fins, wing-t o-body fairings, antennae, and landing gear and doors, for the purpose of extended corrosio n protection and enhanced adhesion.

“Commercial Interior Adhesive” means any material used in the bonding of passenger cabin interior components. These components must meet the Federal Aviation Administration fireworthiness requirements.

“Compatible Substrate Primer” includes two categories: “compatible epoxy primer” and “adhesive primer.” “Compatible epoxy primer” means any primer that is compatible with the filled elastomeric coating and is epoxy based. The compatible substrate primer is an epoxy-polyamide primer used to promote adhesion of elastomeric coatings such as impact-resistant coatings. “Adhesive primer” means any coating that (1) inhibits corrosion and serves as a primer applied to bare metal surfaces or prior to adhesive application, or (2) is appl ied to surfaces that can be expected to contain fuel. Fuel tank coatings are excluded from this category. Comment [A87]: Added for ease of understanding that these materials are specialty coatings

.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-5 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 5 October 20, 1994[ date of amended rule adoption ] “Compliant Material” means any coating, stripper, or solven t that has a reactive organic compound content or composite partial pressure that complies with the applicable limit in Sections D.1, D.2, or J.1

“Confined Space” means any space that (1) is large enough and so configured that an employee can bodily enter and perform assigned work; (2) has limited or re stricted means for entry or exit (for example, fuel tanks, fuel vessels, and other spaces that have limited mean s of entry); and (3) is not suitable for continuous employee occupancy.

“Contact Bond Adhesive” or “Contact Adhesive” means any adhesive intended by the manufacturer to adhere to itself instantaneously upon contact. The ad hesive is applied to both adherends and allowed to become dry, which develops a bond when the adherends are brought together without sustained pressure. for application to both surfaces to be bonded together, is allowed to dry before the two surfaces are placed in contact with each other, forms an immediate bond that is impossible, or difficul t, to reposition after both adhesive-coated surfaces are placed in contact with each other, and does not need sustained pressure or clamping of surfaces after the adhesive-coated surface s have been brought together using sufficient momentary pressure to establish full contact betwee n both surfaces. Contact adhesive does not include rubber cements that are primarily intended for use on paper substrates. Contact adhesive also does not include vulcanizing fluids that are designed and labeled for tire repair only.

“Contact Bond Adhesive

- Specialty Substrates” or “Specialty Contact Adhesive” means any contact adhesive that is intended by the manufacturer to be used for the bonding of nonporous substrates to each other, the bonding of decorative laminate in post-formi ng application, the bonding of decorative laminate to metal, melamine-covered board, or curved surfaces, or the bonding of any substrate to metal, rubber, rigid plastic, or wood veneer not exceeding 1/16 inch in thickness.

“Control” means the reduction, by destruction or removal, of the amount of affected pollutants in a gas stream prior to discharge to the atmosphere.

“Control System” means any combination of pollutant capture system(s) and control device(s) used to reduce discharge to the atmosphere of reactive or ganic compound or toxic air contaminant emissions generated by a regulated operation.

“Corrosion Prevention System” means any coating system that provides corrosion protection by displacing water and penetrating mating surfaces, forming a protective barrier between the metal surface and moisture. Coatings and compounds containing oi ls or waxes are excluded from this category.

“Critical Use and Line Sealer Maskant” means any temporary coating, not covered under other maskant categories, used to protect selected areas of aerospace part s from strong acid or alkaline solutions such as those used in anodizing, plating, chemical milling and pr ocessing 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.

“Cryogenic Flexible Primer” means any 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 (minus 275 degrees Fahrenheit and below).

“Cryoprotective Coating ” means any 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.

“Cyanoacrylate Adhesive” means any fast-setting, single component adhesive that cures at room temperature. Also known as "super glue."STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-6 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 6 October 20, 1994[ date of amended rule adoption ] “Depainting” means the removal of a permanent coating from the outer surface of an aerospace vehicle or
component.

“Depainting Operation” means the use of a chemical agent, med ia blasting, or any other technique to remove permanent coatings from the outer surface of an aerospace vehicle or components. The depainting operation includes washing of the aerospace vehicle or component to remove residual stripper, media, or coating residue.

3. “Detailing or Touch

- up Guns” mean any are small air spray equipment, including air brushes, that operate at no greater than 5 CFM cubic feet per minute air flow and no greater than 50 pounds per square inch gauge (Psig) air pressure and are used to coat small products or portions of products.

“Dip Coat Application” means any process in which a substrate is immersed in a solution (or dispersion) containing the coating material, and then withdrawn.

“Dry Lubricative Material” means any coating consisting of lauric acid, cetyl alcohol, waxes, or other non-cross linked or resin-bound materials which act as a dry lubricant.

4. “Interior Topcoat” means a topcoat used in habitable interior spaces of aircraft.

5. “Electric -/ or Radiation - Effect Coating s ” mean s an electrically conductive or insulative coating, or coatings used on radar and antennae en closuresany coating or coating system engineered to interact, through absorption or reflection, with specific regions of the electromagnetic energy spectrum, such as the ultraviolet, visible, infrared, or micr owave regions. Uses include, but are not limited to, lightning strike protection, electromagnetic pu lse protection, and radar avoidance.

“Electrodeposition” means the application of a coating using a water-based electrochemical bath process. The component being coated is immersed in a bath of the coating. An electric potential is applied between the component and an oppositely charged electrode hanging in the bath. The electric potential causes the ionized coating to be electrically attracted, migrated , and deposited on the component being coated.

“Electrostatic Discharge and Elect romagnetic Interference Coating” means any coating applied to space vehicles, missiles, aircraft radomes, and helic opter blades to disperse static energy or reduce electromagnetic interference.

6. “Electrostatic Application” means using a sufficient charging of atomized paint droplets to cause deposition by electrostatic attraction. This appl ication requires a minimum 60kV power supply.

“Elevated -Temperature Skydrol- Resistant Commercial Primer” means any primer applied primarily to commercial aircraft (or commercial aircr aft adapted for military use) that must withstand immersion in phosphate-ester (PE) hydraulic fluid (Skydrol 500b or equivalent) at the elevated temperature of 150 degrees Fahrenheit for 1,000 hours.

“Epoxy Polyamide Topcoat” means any coating used where harder fi lms are required or in some areas where engraving is accomplished in camouflage colors.

7. “Exempt Organic Compounds” means those compounds listed as exceptions in the definition of

“ Reactive Organic Compounds ” in Rule 102.

“Exterior Primer” means the first layer and any subsequent layers of identically formulated coating applied to the exterior surface of an aerospace vehicle or component wh ere the component is used on the exterior of the aerospace vehicle. Exterior primers are typically used for corrosion prevention, protection from the environment, functional fluid resistance, and ad hesion of subsequent exterior topcoats. Coatings that are defined as specialty coatings are not included under this definition.

8. “Extreme Performance Interior Topcoat” means a topcoat used in interior spaces of aircraft areas requiring a fluid, stain

, or nicotine barrier. Comment [A88]: The District protocol is to

remove d egree symbols, abbreviations, and acronyms. Hence, they are spelled out here and

elsewhere.

Comment [A89]: Moved to be in alphabetical

order.

Comment [A90]: Replaced by the term “electrostatic spray” and relocated it to Rule 102.

Comment [A91]: Exempt organic compound is replaced by exempt compound in Rule 337. An exempt compound definition is being added to Rule 102, Defin itions.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-7 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 7 October 20, 1994[ date of amended rule adoption ] “Fastener Manufacturer” means any stationary source that coats air craft fasteners, such as pins, collars, bolts, nuts, and rivets, with solid-film lubricants for distribution.

“Fastener Sealant” means any sealant applied to a device us ed to join two or more parts together.

9. “Fire Insulation-Resistant (Interior) Coating” means : a coating used to provide a layer of insulation in the event of an aircraft or engine fire.

1. For civilian aircraft, any coating used on pa ssenger cabin interior parts that are subject to the Federal Aviation Administration fireworthiness requirements.

2. For military aircraft, any coating used on parts that are subject to the flammability requirements of MIL-STD-1630A and MIL-A-87721.

3. For space applications, any coating used on parts that are subject to the flammability requirements of SE-R-0006 and SSP 30233.

“Flexible Primer” means any primer that meets flexibility requir ements 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, an d 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.

“Flight Test Coating” means any coating applied to aircraft other than missiles or single-use aircraft prior to flight testing to protect the aircraft from corrosio n and to provide required marking during flight test

evaluation.

“Flow Coat Application” means any coating application system, with no air supplied to the nozzle, where paint flows over the part and the excess coating drains back into the collection system.

“Flush Cleaning” means the removal of contaminants such as dirt, grease, oil, and coatings from an aerospace vehicle or component or application equipment by passing solvent over, into, or through the item being cleaned. The solvent may simply be poured into the item being cleaned and then drained, or be assisted by air or hydraulic pres sure, or by pumping. Hand-wipe cleaning operations where wiping, scrubbing, mopping, or other hand actions are used are not included.

“Fuel Tank Adhesive” means any adhesive used to bond components exposed to fuel and must be compatible with fuel tank coatings.

10. “Fuel Tank Coating” means a ny coating applied to the interior of a fuel tank components or to fuel wetted areas of aircraft to protect it from for the purpose of corrosion and/or bacterial growth inhibition

and to assure sealant adhesion in extreme environmental conditions

.

11. “Grams of ROC Reactive Organic Compound per Liter of Coating

, Less Water and Less Exempt Compounds” means the weight of ROC reactive organic compound per combined volume of ROC reactive organic compound and coating solids and can be calcu lated by the following equation:



### W

s 

### - W
w 

### - W

es 

### Grams(lb) of ROC / l(gal) of coating =

V

m 

### - V

w 

### - V

esSTAFF REPORT

– PARs 330, 337, 349, & 353 Page E-8 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 8 October 20, 1994[ date of amended rule adoption ] Grams of reactive organic compounds W

s - W

w - W

es per liter of coating, less water and less = exempt compounds V

m - V

w - V

es

Where: W

s = Weight of volatile compounds (including water) in grams

W

w = Weight of water in grams

W

es = Weight of exempt organic compounds in grams

V

m = Volume of material in liters

V

w = Volume of water in liters

V

es = Volume of exempt organic compounds in liters

For aerospace coatings that contain reac tive diluents, the grams of reactive organic compound per liter of coating, less water and less exempt compounds, shall be calculated by the following equation:

Grams of reactive organic compounds W

rs - W

rw - W

re per liter of coating, less water and less = exempt compounds V

rm - V

rw - V

re

Where: W

rs = Weight of volatile compounds not consumed during curing in grams

W

rw = Weight of water not consumed during curing in grams

W

re = Weight of exempt compounds not consumed during curing in grams

V

rm = Volume of material not consumed during curing in liters

V

rw = Volume of water not consumed during curing in liters

V

re = Volume of exempt compounds not consumed during curing in liters

12. “Hand Application Method” means the application of a surface coating by manually held nonmechanically operated equipment. Such equipment incl udes paint brush, hand-roller, trowel, spatula, dauber, rag or sponge.

“Hand

- Wipe Cleaning Operation” means the removal of contaminants such as dirt, grease, oil, and coatings from an aerospace vehicle or component by physically rubbing it with a material such as a rag, paper, or cotton swab that has been moistened with a cleaning solvent.

13. “High Temperature Coating” means a ny coating that, during normal use, must designed to withstand temperatures in excess of more than 350 °F degrees Fahrenheit

.

14. “High Volume Low Pressure Spraying” means using spray equipment with air pressure between 0.1 and 10.0 psi and air volume greater than 15.5 cfm per spray gun.

“Insulation Covering” means any material that is applied to foam insulation to protect the insulation from mechanical or environmental damage.

“Interior Topcoat” means any topcoat used inhabitab le interior spaces of aircraft.

“Intermediate Release Coating” means any 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.

“Lacquer” means any 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.

“Limited Access Space” means any internal surfaces or passages of an aerospace vehicle or component

that cannot be reached without the aid of an airbru sh or a spray gun extension for the application of coatings. Comment [A92]: Replaced by the term “high volume low pressure spraying equipment” and

relocated it to Rule 102.

Comment [A93]: Relocated here to be in alphabetical order.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-9 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 9 October 20, 1994[ date of amended rule adoption ] 15. “Maskant

- Chemical Processing” means a coating applied directly to a part to protect surface areas when chemical milling, anodizing, aging, bonding, plating, etching and/or performing other chemical operations on the surface of the part.

“Long Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the aircraft manufacturers’ required performance characteristics following 6,000 hours test ing, used for metal to structural core bonding, and with an adhesive that is specified to be cured at a temperature of 350 degrees Fahrenheit plus or minus 10 degrees Fahrenheit.

“Metalized Epoxy Coating” means any coating that contains relatively large quantities of metallic pigmentation for appearance and/or added protection.

“Mold Release” means any coating applied to a mold surface to prevent the molded piece from sticking to

the mold as it is removed.

“Natural Draft Opening” means any opening in a room, building, or total enclosure that remains open during operation of the facility and that is not connected to a duct in which a fan is installed. The rate and direction of the natural draft through such an opening is a consequence of the difference in pressures on either side of the wall containing the opening.

“Non -Complying C oating” means a coating with a reactive or ganic compound content above a limit specified in Section D.1.

“Noncompliant Material” means any coating, stripper, or solvent that has a reactive organic compound content or composite partial pressure that does not comply with the applicable limit in Sections D.1, D.2, or

J.1.

“Nonstructural Adhesive” means any adhesive that bonds nonloa d bearing aerospace components in noncritical applications and is not covered in any other specialty adhesive categories.

“Opt ical Anti- Reflective Coating” means any coating with a low reflectance in the infrared and visible wavelength ranges that is used for antireflecti on on or near optical and laser hardware.

“Part Marking Coating” means any coatings or inks used to make identifying markings on materials, components, and/or assemblies. These markings may be either permanent or temporary.

16. “Pretreatment Wash PrimerCoating ” means a any organic coating which that contains a small quantity of at least 0.5 percent acid s by weight for surface etching and is applied directly to metal or composite surfaces to provide surface etching, corrosion resistance, adhesion

, and ease of stripping.

17. “Primer” means a the first layer and any subsequent layers of identically formulated coating applied directly to a part for purposes of to the surface of an aerospace vehicle or component. Primers are typically used for corrosion prevention, protection from the environment, functional fluid resistance

, and /or adhesion of subsequent coatings. Primers that are defined as specialty coatings are not included under this

definition.

“Radome” means the nonmetallic protective housing for ele ctromagnetic transmitters and receivers (e.g., radar, electronic countermeasures, etc.).

“Rain Erosion -Resis tant Coating” means any coating or coating system used to protect the leading edges of parts such as flaps, stabilizers, radomes, engine in let nacelles, etc. against erosion caused by rain impact during flight.

“Reactive Diluent” means a liquid which is a reactive organic compound during application and one in which, through chemical and/or physical reactions, su ch as polymerization, 20 percent or more of the reactive organic compound becomes an integral part of a finished material. Comment [A94]: This term and those listed in

Table 337 -2 under adhesive bonding primers are from definitions in SJV Rule 4605.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-10 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 10 October 20, 1994[ date of amended rule adoption ] “Remanufactured Commercial Aircraft Part” means any aerospace componen t that is built as a spare part or replacement part subject to an existing commercial aircraft specification.

18. “Repair” means recoating of previously coated product due to damage to the coating following normal painting operations.

“Rocket Motor Bonding Adhesive” means any adhesive used in rocket motor bonding applications.

“Rocket Motor Nozzle Coating” means any catalyzed epoxy coating system used in elevated temperature applications on rocket motor nozzles.

“Rubber

- Based Adhesive” means any quick setting contact cement that provides a strong, yet flexible bond between two mating surfaces that may be of dissimilar materials.

“Scale Inhibitor” means any coating that is applied to the surfac e of a part prior to thermal processing to

inhibit the formation of scale.

“Screen Print Ink” means any ink used in screen printing processes during fabrication of decorative

laminates and decals.

“Seal Coat Maskant” means any overcoat applied over a mask ant to improve abrasion and chemical resistance during production operations.

19. “Sealant” means a ny coating material used to prevent the in trusion applied for the purpose of filling voids and providing a barrier against penetration of water, fuel , air, or other fluids or vaporsliquids or solids from certain areas of aerospace vehicles or components

. There are two categories of sealants: extrudable/rollable/brushable sealants and sprayable sea lants. Sealants are a type of specialty coating.

20. “Sealant Bonding Primer” means a coating applied in a very thin film to a part or product for the purpose of providing a primer for a subsequent coat of silicone sealant.

“Sealant Product” means any sealant and sealant primer. Sealant products are a type of coating.

21. “ Self PrimingSelf-Priming Topcoat” means a ny coating topcoat that is applied directly to a part or product that is not subsequently overcoatedan uncoat ed aerospace vehicle or component for purposes of corrosion prevention, environmental pr otection, and functional fluid resistance. More than one layer of identical coating formulation may be ap plied to the vehicle or component

.

“Short Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the manufacturers’ required performance ch aracteristics following 1,000 hours testing, used for metal to metal and metal to structural core bonding, and with an adhe sive which is specified to be cured at a temperature of 350 degrees Fahrenheit plus or minus 10 degrees Fahrenheit.

“Silicone Insulation Material” means any insulating material applied to exterior metal surfaces for protection from high temperatures caused by atmosphe ric friction or engine exhaust. These materials differ from ablative coatings in that they are not “sacrificial.”

“Solid Film Lubricant” means any very thin coating consisting of a binder system containing as its chief pigment material one or more of the following: molybdenum, graphite, polytetrafluoroethylene (PTFE), or other solids that act as a dry lubricant between faying surfaces.

“Solids” mean the non-volatile portion of the coating which after drying makes up the dry film.

“Solvent” means any liquid containing any reactive organi c compound or any toxic air contaminant, which is used as a diluent, thinner, dissolver, viscosity redu cer, cleaning agent, drying agent, preservative, or other

similar uses. Comment [A95]: Added for ease of understanding the relationship between sealants and specialty coatings

.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-11 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 11 October 20, 1994[ date of amended rule adoption ] “Solvent Cleaning” means any activity, operation, or process (including, but not limited to, surface preparation, cleanup, or wipe cleaning) performed outs ide of a solvent cleaning machine, that uses solvent to remove uncured adhesives, uncured coatings, uncu red inks, uncured polyester resin material, uncured sealant, or other contaminants, including, but not limite d to, dirt, soil, oil, lubricants, coolants, moisture, fingerprints, and grease, from parts, products, tools, machinery, application equipment, and general work areas. Cleaning spray equipment used for the application of coating, adhesive, ink, polyester resin material,

or sealant is also considered to be solvent cleani ng irrespective of the spray material being cured.

“Solvent Cleaning Machine” means any device or piece of equipment that uses solvent liquid or vapor to remove soils, moisture, or other contaminants from the surfaces of materials. Types of solvent cleaning machines include, but are not limit ed to, batch cold, batch vapor, in-l ine cold, in-line vapor, remote reservoir, and gas-path solvent cleaners. Buckets, p ails, and beakers with capacities of 3.785 liters (1.00 gallon) or less are not considered solvent cleaning ma chines. However, the use of such a container or similar containers (e.g., hand-held spray bottles) wi th a liquid solvent for cleaning is considered to be solvent cleaning. Any device or piece of equipment used exclusively for stripping shall not be considered to be a solvent cleaning machine.

“Sonic and Acoustic Applications” means the use of aerospace materials on aerospace components that are subject to mechanical vibration and/or sound wave cavitation.

22. “Space Vehicle Coating” means a ny coating applied to vehicles designed to travel beyond the earth's atmosphere.

“Specialized Function Coating” means any 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.

“Specialty Coating” means any coating that, even though it meets the definition of a primer, topcoat, or self-priming topcoat, has additional performance crit eria beyond those of primers, topcoats, and selfpriming topcoats for specific applications. These perfor mance 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. The reactive organic compound content limit for the individual specialty coatings are lis ted in Section D.1, Table 337-2. Definitions for each specialty coating category are provide in Section C.

“Spray Gun” means any device that atomizes a coating or other material and projects the particulates or

other material onto a substrate.

23. “Stripper” means a precursor organic compound applied to remove temporary coating, maskant for chemical processing, paint or residue any liquid that is applied to a surface to remove cured or dried coatings such as primers, adhesives (e.g., debondin g or unglueing), topcoats, and temporary protective coatings

.

24. “Structural Autoclavable Adhesive” means a ny coating adhesivewhich is applied for the purpose of bonding structural components together us ed to bond load-carrying aerospace components that is cured by heat and pressure in an autoclave

.

“Structural Nonautoclavable Adhesive” means any adhesive cured under ambient conditions that is used to bond load-carrying aerospace components or for othe r critical functions, such as nonstructural bonding in the proximity of engines.

“Surface Preparation” means the removal of contaminants from the surface of an aerospace vehicle or component or the activation or reactivation of the surfac e in preparation for the application of a coating. Comment [A96]: Solvent, solvent cleaning , and solvent cleaning machine are the same definit ions

found in Rule 321. Solvent includes any liquid containing any toxic air contaminant.

Comment [A97]: Modeled on 40 CFR 63. 742

and SJV Rule 4605 defin itions. Industry requested clarification of debonding and unglueing provisions. In response, staff added text on stripping cured adhesives. Stripper material limits are in Rule

337.D.2.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-12 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 12 October 20, 1994[ date of amended rule adoption ] 25. “Temporary Protective Coating” means a ny coating applied to a part to protect it from mechanical and environmental damage during manufact uring provide scratch or corrosion protection during manufacturing, storage, or transportation

. Two types include peelable protective coatings and alkaline removable coatings. These materials are not in tended to protect against strong acid or alkaline solutions. Coatings that provide this type of protection from chemical processing are not included in this

category.

“Thermal Control Coating” means any coating formulated with specific thermal conductive or radiative properties to permit temperature control of the substrate.

26. “Topcoat” means a ny coating applied over a primer or intermediary coating on an aerospace vehicle or component for purposes such as appearance, identification , camouflage, or protection. Coatings that are defined as specialty coatings are not included under this definition.

27. “Touch up-Up ” means that portion of the coating operation which is separate from the main coating process but necessary to cover minor impe rfections or to achieve coverage as required.

“Touch

- Up and Repair” means that portion of the coating operation that is the incidental application of coating used to cover minor imperf ections in the coating finish or to achieve complete coverage. This definition includes out-of-sequence or out-of-cycle coating.

28. “Transfer Efficiency” means the ratio of the weight of coating solids adhering to the object being coated to the weight of coating solids used in the application process, expressed as a percentage.

“Type I Chemical Milling Maskant” see the “Chemical Milling Maskant” definition

.

“Type II Chemical Milling Maskant” see the “Chemical Milling Maskant” definition

.

“Type I Etchant” means any chemical milling etchant that contains varying amounts of dissolved sulfur

and does not contain amines.

“Type II Etchant” means any chemical milling etchant that is a strong sodium hydroxide solution containing amines.

“Viscosity” means the internal friction of a liquid that makes it resistant to flow.

“Wet Fastener Installation Coating” means any primer or sealant applied by dipping, brushing, or daubing to fasteners that are instal led before the coating is cured.

29. “Wing Coating” means a ny corrosion-resistant coating that is resilient enough to withstand the flexing of the aircraft wings.

D. Requirements

- – Reactive Organic Compound (ROC) Limits

1. A No person shall not apply any coating or specify solicit the use of any coating on any aerospace vehicle or component subject to the provisions of this rule, which, as applied, emits or may emit

contains reactive organic compounds into the atmosphere in excess of the limits shown in the

table s below. These limits are expressed in grams of reactive organic compound per liter or pounds per gallon of coating

, less water and less exempt organic compounds: Comment [A98]: This term has been relocated to

Rule 102.

Comment [A99]: Our practice is to improve text flow by changing the sentence structure in this

manner.

Comment [A100]: ARB suggested the text changes in a letter dated February 2, 1995.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-13 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 13 October 20, 1994[ date of amended rule adoption ] Table 337-1: Reactive Organic Compound Content Limits for Coatings Other than Specialty Coatings (Grams of Reactive Organic Compound per Lit er, Less Water and Less Exempt Compounds)

Coating Type ROC Limit

Effective [ date of amended rule adoption ]

Exterior Primer 350

Primer 350
Self-Priming Topcoat 420
Topcoat 420
Type I Chemical Milling

Maskant 250

Type II Chemical Milling

Maskant 160

Table 337-2: Reactive Organic Compound Content Limits for Specialty Coatings (Grams of Reactive Organic Compound per Lite r, Less Water and Less Exempt Compounds)

Coating Type ROC Limit
g/l Effective Before [ 24 months

after the date of

amended rule

adoption ] lb/gal Effective On

and After [ 24 months

after the date of

amended rule

adoption ] Ablative Coating 600 600

Adhesion Promoter 850 250
Adhesive Bonding Primer s : 250 2.1

New Commercial Aircraft 250 250
All Military Aircraft 805 805

Remanufactured Commercial Aircraft Parts 805 805
Sonic and Acoustic Applications 805 805
Long Term 250 250

Short Term 250 250

Adhesives:

Commercial Interior Adhesive 760 760
Cyanoacrylate Adhesive 1020 1020

Fuel Tank Adhesive 620 620

Nonstructural Adhesive 250 250
Rocket Motor Bonding Adhesive 890 890

Rubber-Based Adhesive 850 850

Structural Autoclavable Adhesive 50 50

Structural Nonautoclavable Adhesive 850 850
Antichafe Coating 600 420
Barrier Coating 420 420
Bearing Coating 620 620
Caulking and Smoothing Compounds 850 850
Chemical Agent-Resistant Coating 550 550
Clear Coating 520 520
Commercial Exterior Aerodynamic Structure

Primer 350 350 Comment [A101]: 40CFR63, Subpart GG, coating types were c ondensed into those in Table

337

- 1. Subpart GG limits were compared to existing

Rule 337 limits and those found in other air districts.

Table 337 -1 figures reflect limits that have been achieved in practice.

Comment [A102]: Coating types from EPA’s CTG for this source category were added to Table

337

- 2. The limits in that guidance document were compared to those in other air districts. Lower

ROC -content limits that have been achieved in practice were include d in lieu of the limits recommended in the CTG. As noted below, some subcategories and limits were based on other air

district rules.

Comment [A103]: ARB suggested lowering the

limit for adhesion promoter to 250 g/l, Antichafe coating to 420 g/l, and fastener sealant to 600 g/l

based on limits in other air districts. A 24

- month period for phasing

- in the new limits is provided to

allow sale thr ough and use of already purchased

material.

Comment [A104]: Adhesive bonding primer limits and subcategories were modeled on those

found in the SC and SJV rules.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-14 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 14 October 20, 1994[ date of amended rule adoption ] Coating Type ROC Limit
g/l Effective Before [ 24 months

after the date of

amended rule

adoption ] lb/gal Effective On

and After [ 24 months

after the date of

amended rule

adoption ] Compatible Substrate Primer 350 350
Corrosion Prevention System Compound 710 710
Cryogenic Flexible Primer 350 350
Cryoprotective Coating 600 600
Dry Lubricative Material

Fastener Manufacturing 120 1120
Nonfastener Manufacturing 675 5.6675

Electric - /or Radiation

- Effect 800 6.7800
Electrostatic Discharge and Electromagnetic Interference Coating 800 800

Elevated-Temperature Skydrol-Resistant

Commercial Primer 350 350

Epoxy Polyamide Topcoat 660 660
Extreme Performance Interior Topcoat 420 3.5420

Fastener Sealant 675 600
Fire Insulation Coating 600 5
Fire-Resistant (Interior) Coating 600 600

Flexible Primer 350 350
Flight-Test Coatings:

Missile or Single Use Aircraft 420 420

All Other 600 600
Fuel Tank Coating (Excluding Fuel Tank Adhesive) 720

420 6

420 High

- Temperature Coating 720 6720
Interior Topcoat 340 2.8340
Insulation Covering 740 740
Intermediate Release Coating 750 750
Lacquer 830 830
Maskant-Chemical Processing 600 5

Maskants:

Bonding Maskant 1,230 1,230

Critical Use and Line Sealer Maskant 1,020 1,020

Seal Coat Maskant 1,230 1,230
Metallized Epoxy Coating 700 700

Mold Release 780 780
Optical Anti-Reflective Coating 700 700
Part Marking Coating 850 850

Pretreatment Wash PrimerCoating 400

780 3.3

780

Primer 350 2.9
Rain Erosion-Resistant Coating 600 600
Rocket Motor Nozzle Coating 660 660

Scale Inhibitor 880 880

Screen Print Ink 840 840 Comment [A105]: Dry lubricative material limits and subcategories were modeled on those

found in the SC and SJV rules.

Comment [A106]: SC, SJV, and VC rules include a 675 g/l fastener sealant limit . The 600 g/l

limit is based on a limit in the SJV Rule 4605.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-15 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 15 October 20, 1994[ date of amended rule adoption ] Coating Type ROC Limit
g/l Effective Before [ 24 months

after the date of

amended rule

adoption ] lb/gal Effective On

and After [ 24 months

after the date of

amended rule

adoption ]

Sealant 600 5

Extrudable/Rollable/Brushable Sealant 280 280
Sprayable Sealant 600 600
Sealant Bonding Primer 720 6
Self Priming Topcoat 420 3.5

Silicone Insulation Material 850 850

Solid Film Lubricants

Fastener Manufacturing 250 250

Fastener Installation 880 880
Nonfastener Manufacturing 880 880
Space Vehicle Coating:

Electrostatic-Discharge 800 6.7800

Other 1

, 000 8.31,000
Specialized Function Coating 890 890
Temporary Protective Coating 250 2.1250

Topcoat 420 3.5
Thermal Control Coating 800 800
Wet Fastener Installation Coating 675 675
Wing Coating 750 6.3750

2. A No person shall not apply any stripper or specify solicit the use of any stripper unless it complies with one or both of the following:

a. The stripper contains less than 400 300 grams / of reactive organic compound per liter of ROC of material (2.50 pounds of reactive organic compound per gallon)

.

b. The stripper has a true vapor reactive organic compound composite partial pressure of less than 10 mm Hg equal to or less than 9.5 millimeters of mercury at actual usage temperature20 degrees Celsius

.

3. Sources A person may elect to use an add-on exhaust control equipment system to achieve as an alternative to meeting the requirements compliance with the provisions of Section s D .1, D.2, E,

and J , provided that the control equipment meets all of the applicable requirements of sections a.

and b. below are met

. Such control equipment must be ap proved in advance by the Control

Officer. Any person choosing to install such control equipment shall obtain an Authority to Construct from the District prior to installation.

a. The control device shall reduce emissions from an emission collection system by at least 95 percent by weight.

b. The emission collection system which collects and transports emissions to an air pollution control device shall collect at least 90 percent by weight of the emissions generated by the sources of emissions. a. The overall efficiency (the capture efficiency multiplied by the control device efficiency) of the total system shall not be less than 85.5 percent, by weight. Alternatively, the control device reactive organic compound exha ust concentration shall not exceed 10 parts Comment [A107]: Solid film lubricants subcategories and limits mirror those found in the SC, SJV, and VC rules.

Comment [A108]: Change made to 300 g/l per suggestion from the Air Resources Board.

Comment [A109]: Reactive organic compound composite partial pressure is more contemporary

tha n true vapor pressure . SJV and VC have reduced the limit to 9.5 mm Hg at 20 degrees C.

Comment [A110]: Following other air district methods, sources may comply with the S ection E(application equipment) and Section J (solvent ROCcontent or pressure) provisions by using an add

- on control system.

Comment [A111]: Similar to the Rule 321.N.1 provision.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-16 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 16 October 20, 1994[ date of amended rule adoption ] per million by volume as propane or ot her limit approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer.

b. Combustion temperature shall be continuously monitored when operating a thermal

incinerator.

c. Inlet and exhaust gas temperatures shall be continuously monitored when operating a catalytic incinerator.

d. Control device efficiency shall be continuously monitored when operating a carbon

adsorber or a control device other than a thermal or catalytic incinerator.

e. Compliance through the use of an add-on control system shall not result in affected pollutant emissions in excess of the affected pollutant emissions that would result from compliance with Sections D.1, D.2, E, and J.

E. Requirements

- – Application Equipment

A No person shall not apply coatings subject to the provisions of this rule except by using properly operated unless the application is performed with equipment and by operating according to the manufacturers operating guidelines. In addition, except as provided in Section D.3, the application method employed shall be one of the following :

1. Electrostatic spray application, or

2. Flow coat application, or

3. Dip coat application, or

4. Roll coater, or

45 . High volume

, low pressure spraying (HVLP) equipment , or

56 . Electrodeposition, or

67 . Hand application methods, or

78 . Detailing or touch-up guns, or

89 . Any other coating application method that approved by the Control Officer, the Air Resources Board, and the Environmental Protection Agency, achieves that has a coating transfer efficiency of at least equivalent to or greater than 65 percent efficiency as demonstrated measured by using the test method specified in Section I.4.

10. Except as otherwise provided in Section E.11, air-atomized spray may only be used for the application of contact adhesives or specialty contact adhesives.

11. For adhesive products and sealan t products with an as applied viscosity of 200 centipoise or greater, airless spray, air-assisted airles s, and air-atomized spray may be used.

F. Requirements

- – Closed ContainersGeneral Operating

Any person who owns, operates, or uses any surface coating or depainting equipment for any aerospace vehicle or component coating operation shall meet the following requirements: Comment [A112]: Subsections d - f mirror Rule 353.I provisions.

Comment [A113]: Similar to provision in Rule 321.N.6. ( Reactive organic compound changed to affected pollutant to include TACs.)

Comment [A114]: ARB suggested the addition

of according to the manufacturers operating guidelines.

Comment [A115]: The potential new Section E provisions are similar to those f ound in the SJV Rule

4653 and the SC Rule 1168. The Distr ict pr oposes them to comply with the “every feasible control technique” requirements in state la w.

Comment [A116]: SC Rule 1168 and SJV Rule

4653 include roll coater.

Comment [A117]: Stems from SJV Rule

4653.5.2.9.

Comment [A118]: Modeled on SC Rule 1168(c)(5)(H).STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-17 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 17 October 20, 1994[ date of amended rule adoption ] 1. All ROC reactive organic compound -containing materials, used or unused, including but not limited to surface coatings, thinners, cleanup solvents, strippers, or surface preparation materials

shall be stored and disposed of in closed nonabsorbent and nonleaking containers equipped with tight-fitting covers. All covers shall be in place unless adding material to or removing material

from the containers , and opened only during extraction or introduction of material for mixing, use or storage the containers are empty, or doi ng maintenance/inspection of the containers

.

2. All application equipment, ventilation system, an d emission control equipm ent shall be installed, operated, and maintained consistent with the manufacturer’s specificat ions.

3. Waste solvent, waste solvent residues, and any other waste material that contains reactive organic compounds shall be disposed of by one of the following methods:

a. A commercial waste solvent reclamation service licensed by the State of California.

b. At a facility that is federally or state license d to treat, store or dispose of such waste.

c. Recycling in conformance with Section 25143.2 of the California Health and Safety

Code.

4. All covers, valves, drain plugs, and other closure devices designed to reduce surface coating, stripper, or solvent evaporation shall not be re moved or opened except to process work or to perform monitoring, inspections, maintenance, or repa irs that require the removal of the covers or

other closure devices.

5. Any surface coating, stripper, or solvent spil ls shall be wiped up immediately and the used absorbent material (e.g., cloth, paper, sand, sawdust, etc.) shall be stored in closed containers that

are handled in accordance with Section F.1.

6. The handling and transfer of coatings, strippers, and cleaning solvents to or from enclosed systems, vats, waste containers, and other cleanin g operation equipment that hold or store fresh or spent coatings, strippers, and cleaning solvents shall be conducted in such a manner to minimize spills

.

7. Containers used to store coating, solvent, or any waste material that contains reactive organic compounds subject to this rule shall be marked or clearly labeled indicating the name of the material they contain.

G. Requirements

- – Manufacturer Labeling

1. Each container of any coating subject to this rule shall display the date on which the contents were manufactured or a code indicating the date of manufacture. Each manufacturer of such coatings

shall file with the Air Pollution Control Officer and the Executive Officer of the California Air Resources Board an explanation of each code.

2. Each container of any coating subject to this rule shall display a statement of the manufacturer's recommendation regarding thinning of the coating. This recommendation shall not apply to the thinning of coatings with water. The recomme ndation shall specify that the coating is to be employed without thinning or diluting under normal environmental and application conditions unless any thinning recommended on the label for normal environmental and application conditions does not cause a coating to exceed its applicable standard for reactive organic compound content

.

3. Each container of any coating subject to this rule shall display the maximum ROCreactive organic compound content of the coating, as applied, and after any thinning as recommended by the

manufacturer. ROC Reactive organic compound content shall be displayed as g/lgrams per liter or Comment [A119]: The housekeeping provisions are similar to requirements found in Rule 321.D.

Comment [A120]: ARB recommendation.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-18 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 18 October 20, 1994[ date of amended rule adoption ] lb/galpounds per gallon of coating

, less water and less exempt organic compounds. The VOC volatile organic compound content may be displayed instead of the ROC reactive organic compound content as long as the manufacturer's definition of VOC volatile organic compound is

consistent with the definition of ROC reactive organic compound contained in District Rule 102

, Definitions

. ROC Reactive organic compound content displayed may be calculated using product

formulation data and the formula in Section C , or may be determined using the test method in

Section I .1

.

H. Requirements -

– Recordkeeping

Any Persons person subject to this rule shall comply with the following requirements. Any owner or operator of any stationary source comprised of more than one facility may comply with the following requirements on a facility basis.

1. Maintain a current listingfile of all ROCreactive organic compound -containing materials in use at their facilitythe stationary source subject to this rule

. This listing shall include: The file shall provide all of the data necessary to evaluate compliance and shall include the following information, as applicable:

a. material name and manufacturer identification (e.g., brand name, stock identification number) ;

b. application method;

c. material type , and ma nufacturer’s specific use instructions (e.g., specific use for which the material is intended), type operation (e.g., coating, stripping, or solvent cleaning), and, for coating operations, the coating type from Table 337-1 or Table 337-2 and equipment coated ;

d. specific mixing ratiodata (e.g., component volumes or weights) of each component for each batch sufficient to determine the mixture’s reactive organic compound content ;

e. the corresponding reactive organic compound limit(s) from Sections D.1, D.2, and J.1 and the maximum actual as applied ROCreactive organic compound content of coating used. If complying using the “reactive organic compound composite partial pressure” method only, provide the actual reactive organi c compound composite partial pressure of the materials used less water and less exempt compounds as applied (including thinning solvents).; and

f. current coating, stripper, and solvent ma nufacturer specification sheets, Material Safety Data Sheets, product data sheets, or air quality data sheets, which list the reactive organic compound content of each material in use at the stationary source subject to this rule

. Compliance with this provision may be done by ensuring the manufacturer’s specifications are listed on the product container

.

2. Current coating manufacturer specification sheets , Material Safety Data Sheets or current air quality data sheets, which list the ROC content of each material in use at their facility, shall be

available for review on site.

32 . Maintain purchase records identifying the type or name and the volume of material purchased for

each ROCreactive organic compound -containing material purchased for use at the stationary

source

. The records shall include, but not be limited to, the following:

a. material name and manufacturer identification (e.g., brand name, stock identification number); and Comment [A121]: Inserting and the formula in

Section C follows an ARB suggestion.

Comment [A122]: Our protocol is to specify requirements are on a stationary source basis. By adding in use at the stationary source

, misinterpretations that the requirements are on a facility basis should be avoided.

Comment [A123]: Essentially the same text

found in Rule 353.O.1.

Comment [A124]: Moved to 337.H.1.f.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-19 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 19 October 20, 1994[ date of amended rule adoption ] b. material type (e.g., coating type from Table 337-1 or Table 337-2, cleanup solvent, stripper, etc.).

3. Maintain records of the disposal method each time waste solvent, waste solvent residue, or other waste material that contain reactive organic compounds is removed from the stationary source for disposal.

4. Maintain For each material maintained in response to Section H.1.a, maintain at a minimum, on a monthly basis for compliant material and on a daily basis for noncompliant material, a record of

the following:

a. volume used (gallons per day, gallons per month),;

b. ROCreactive organic compound content (grams per liter or pounds per gallon); and

c. and resulting ROCreactive organic compound emissions (pounds per day, pounds per month)of each ROC-containing material used

.

These records shall be summarized for each calenda r year and submitted to the District by March 1 of the following year.

5. Operators of facilities For any stationary source that use s non-compliant coating materials with compliance achieved through the operation of emission control equipment as an alternative to meeting the requirements of Sections D.1, D.2, E, or J, shall maintain daily records of key operating parameter values and maintenance procedures which that demonstrate continuous operation and compliance of the emission control device system during periods of emission producing activities shall be maintained

. These parameters shall include, but not be limited to:

a. Hours of operation;

b. All maintenance work that requires the emission control system to be shut down;

c. All information needed to demonstrate continuous compliance with Section D.3, such as temperatures, pressures, and/or flow rates.

6. All Any records required by to be maintained pursuant to this rule shall be kept on site for at least 2 years unless a longer retention period is otherw ise required by state or federal regulation(s). Such records shall be readily available for shall be retained and available for inspection by the Control Officer or designated repr esentative upon request for the previous 36 month period and review by the District

.

7. Any person claiming an exemption under Section B.1 shall maintain:

a. Daily records of the volumes in gallons of non complying coating materials used by each separate formulation at the stationary source.

b. Annual running totals, from January 1 of each calendar year, of the volume in gallons of non-complying coating materials used at the stationary source for:

1) Each separate formulation.

2) All formulations

. Comment [A125]: Moved the annual reporting requirements to Section L per industry suggestion.

Comment [A126]: Subsections a - c are from

Rule 321.R.1.c.

Comment [A127]: EPA recommended daily recordkeeping for non-complying coatings.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-20 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 20 October 20, 1994[ date of amended rule adoption ] I. Requirements

– Compliance Provisions and Test Methods

1. ROC content of a coating Coatings and solvent reactive organic compound content shall be determined measured using EPA by the Environmental Protection Agency Reference Method 24,

its constituent methods

, or an equivalent method approved by the Control Officer, ARB and EPA Environmental Protection Agency, the Air Resources Board, and the Control Officer . The determination of exempt compounds shall be performed in accordance with ASTM D 4457- 851991, “ Standard Test Method for Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings by Direct Injection i nto a Gas Chromatograph,” ASTM International

. Alternatively, determination of exempt compounds may be performed in accordance with the South Coast Air Quality Management District Method 303- 91, “Determination of Exempt Compounds,” August 1996. The reactive organic compound content of materials containing 50 grams of reactive organic compound per liter or less shall be determined by the South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography- Mass Spectrometry,” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer.

2. Compliance with Section D.3.a The control device efficiency for reactive organic compound

emissions shall be determined by using ARB Method 100 or EPA Environmental Protection Agency Test Method s 25 , 25A, the South Coast Air Quality Management District Method 25.1,

“ Determination of Total Gaseous Non- Methane Organic Emissions as Carbon,” February 1991, or the South Coast Air Quality Management District Method 25.3, “ Determination of Low Concentration Non-Methane Non-Ethane Organic Compound Emissions from Clean Fueled Combustion Sources,” March 2000, as applicable. Environmental Protection Agency Test Method 18 or Air Resources Board Method 422, “ Exempt Halogenated VOCs in Gases ,” September 12, 1990, shall be used to determine emissions of exempt compounds

. or a method determined to be equivalent and approved by the Control Officer, ARB, and EPA.

3. Compliance with Section D.3.b The capture efficiency for reactive organic compound emissions

shall be based on EPA Guidelines for Developing Capture Efficiency Protocols from 55 FR 26865, July 1, 1990determined by verifying the use of a Permanent Total Enclosure and 100 percent capture efficiency as defined by Environmental Protection Agency Method 204, “ Criteria for and Verification of a Permanent or Temporary Total Enclosure.” Alternatively, if an Environmental Protection Agency Method 204 defined Permanent Total Enclosure is not employed, capture efficiency shall be determined using a minimum of three sampling runs subject to data quality criteria presented in the Environmental Protection Agency technical guidance

document “ Guidelines for Dete rmining Capture Efficiency, January 9, 1995.” Individual capture efficiency test runs subject to the Environmental Protection Agency technical guidelines shall be determined by:

a. The Temporary Total Enclosure approach of Environmental Protection Agency Methods

204 thro ugh 204F; or

b. The South Coast Air Quality Management District “ Protocol for Determination of Volatile Organic Compounds (VOC) Capture Efficiency, ” May 1995.

4. Compliance with Section E.8 Application equipment coating transfer efficiencies shall be

determined measured using South Coast Air Quality Management District Method “ Spray Equipment Transfer Efficiency Test Procedure of for Equipment User, ” May 24, 1989.

5. Compliance with Section D.2 Reactive organic compound composite partial pressures shall be

determined measured using ASTM D 2879- 861997

, “ Standard Test Method for Vapor PressureTemperature Relationship and Initial Decompositio n Temperature of Liquids by Isoteniscope,” ASTM International, in combination with the formula in the Rule 102 definition of “ reactive organic compound composite partial pressure,” manufacturer's specified vapor reactive organic Comment [A128]: EPA recommended referring

to SC Method 313 for d etermining ROC content of materials containing < 50 g/l.

Comment [A129]: These changes follow EPA’s

recommendation that the District model the provisions on SC Rule 1122(h)(7)(B) text.

Comment [A130]: EPA recommended that the

District model the provisions on SC Rule 1122(h)(7)(A) text.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-21 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 21 October 20, 1994[ date of amended rule adoption ] compound composite partial pressure, or an accepted scientific reference approved the Environmental Protection Agency, the Air Resources Board, and the Control Officer

.

6. The control device efficiency for toxic air cont aminant emissions that are not reactive organic compounds shall be determined using:

a. an Environmental Protection Agency approved test method or methods, or

b. in the case where there is no Environmental Protection Agency approved test method, a District approved detection method applicable for each target toxics specie.

c. the Control Officer may require more than one test method on any emission control device where necessary to demonstrate that the overall efficiency is at least 85.5 percent by weight in reducing emissions of reac tive organic compounds and/or toxic air contaminants. Any technique to convert “parts per million by volume” test method

res ults to either 1) “parts per million by we ight,” or 2) “mass emission rates” (e.g., pounds per hour) shall first be approved by th e Control Officer and, if such approval is not provided, then the technique shall not be used to show compliance with this rule.

7. The capture efficiency for toxic air contam inant emissions that are not reactive organic compounds shall be determined by using the meth ods described in Section I.3 modified in a manner approved by the District to quantify the mass of liquid or gaseous reactive organic compounds and/or toxic air contaminants.

8. The active and passive solvent losses from spray gun cleaning systems shall be determined using South Coast Air Quality Management District's, "General Test Method for Determining Solvent Losses from Spray Gun Cleaning Systems," dated October 3, 1989. The test solvent for this determination shall be any lacquer thinner with a minimum reactive organic compound composite partial pressure of 105 millimeters of mercury at 20 degrees Celsius, and the minimum test temperature shall be 15 degrees Celsius.

9. Viscosity shall be determined by ASTM D 1084-8 8, “Standard Test Methods for Viscosity of Adhesives,” ASTM International.

10. Emissions of reactive organic compounds from th e exhaust of an emission control system shall be measured by the Environmental Protection Agency Method 25, in combination with Environmental Protection Agency Method 18 or the California Air Resources Board Method 422, “Exempt Halogenated VOCs in Gases,” September 12, 19 90 (to determine emissions of exempt compounds).

11. When more than one test method or set of test methods are specified for any testing, a test result showing an exceedance of any limit of this rule shall constitute a rule violation

.

12. The Environmental Protection Agency test methods in effect on [ date of amended rule adoption ] shall be the test methods used to meet the requirements of this rule.

J. Requirements

– Solvent Cleaning Associated with Surface Coating of Aerospace Vehicles and Components

Section J requirements shall apply to any person performing solvent cleaning associated with surface coating of aerospace vehicles or com ponents, including, but not limited to, use of wipe cleaning cloths, hand-held spray bottles, squirt bott les, aerosol products, and the cleaning of application equipment. The following requirements become effective [ one year from the date of amended rule adoption ] and are in addition to the general operating requirements specified in Section F. Comment [A131]: Essentially the same as Rule 321.P.4 provisions.

Comment [A132]: Similar to the Rule 321.P.3 requirements.

Comment [A133]: Added per the EPA recommendation in the Technical Support Document for SJV Rule 4605 (June 2009).

Comment [A134]: Section J stems from similar solvent cleaning provisions in Rule 321.M.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-22 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 22 October 20, 1994[ date of amended rule adoption ] 1. Solvent Requirements

Except when using an emission control system that meets the requirements of Section D.3, no person shall use any solvent to perform solvent cleaning which exceeds the following limits:

a. When Performing Surface Preparation for Coating Application and Cleanup (Other than Spray Application Equipment Cleaning):

1) 200 grams of reactive organic compound per liter (1.67 pounds of reactive organic compound per gallon) of material, or

2) reactive organic compound composite partial pressure of 45 millimeters of mercury at 20 degrees Celsius.

b. When Performing Solvent Cleaning of Spray Application Equipment: 25 grams of reactive organic compounds per liter (0.21 pounds of reactive organic compound per gallon) of material. In lieu of meeting the reactive organic compound-content limit, a person may use an enclosed cleaning system, or equipment that is proven to the satisfaction of the Control Officer to be equ ally effective as an enclosed cleaning system at controlling emissions. “Equal effectiveness” o f an alternative cleaning system shall be determined by the test method referenced in Section I.8 of this rule. If an enclosed cleaning system is used, it shall totally enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing, and draining procedures, and it shall be used according to the manufacturer’s recommendations and be closed when not in use.

2. Cleaning Devices and Methods. Except for solvent cleaning of spray application equipment, any person performing solvent cleaning with a solvent containing more than 25 grams of reactive organic compounds per liter of material shall use one or more of the following cleaning devices or

methods:

a. Wipe cleaning where solvent is dispensed to wipe cleaning materials from containers that are kept closed to prevent evaporation, excep t while dispensing solvent or replenishing the solvent supply, and where wipes are st ored in closed containers to prevent evaporation when not in use;

b. Application of solvent from hand-held spra y bottles, squirt bott les, or other closed containers with a capacity of one liter or less; or

c. Non-atomized solvent flow, dip, or flush cleaning method where pooling on surfaces being cleaned is prevented or drained, and al l solvent runoff is collected in a manner that enables solvent recovery or disposal. Th e collection system shall be kept closed to prevent evaporation except while collecting so lvent runoff or emptying the collection

system.

K. Compliance Schedule

Any person who owns, operates, or us es any application equipment to su rface coat any aerospace vehicles or components shall meet the following compliance schedule:

1. By [ 30 days from the date of amended rule adoption ], comply with Section F, Requirements - General Operating.

2. By [ six months from the date of amended rule adoption ], comply with the recordkeeping provisions in the following Sections:

a. H.1.d - mixing data, Comment [A135]: Modeled on SC Rule 1124(c)(1)(A) and SJV Rule 4605.5.2.1.

Comment [A136]: ARB and EPA recommended a 25 g/l limit on the solvent's ROC content.

Comment [A137]: Aerospace industry spokespersons indicated that some application equipmen t cleaning requires with a higher ROCcontent solvent. In response, a provision modeled on

Rule 321.M.3 is included.

Comment [A138]: Similar to Rule 321.M.2.STAFF REPORT

– PARs 330, 337, 349, & 353 Page E-23 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 337 337 - 23 October 20, 1994[ date of amended rule adoption ] b. H.1.e - reactive organic compound content data,

c. H.2 - purchase records,

d. H.3 - waste disposal records, and

e. H.4 - daily records for noncompliant materials.

3. By [ one year from the date of amended rule adoption ], comply with the Section J and Section M requirements.

4. By [ date of amended rule adoption ], comply with all other provisions of this rule.

L. Reporting Requirements

Submittal of an annual report to the District is required if:

• A person holds a permit for equipment subj ect to the requirements of this rule, or

• A person is subject to the requirements of this rule and applies non-complying coatings.

The annual report shall be due March 1 and it shall contain the following information for the previous calendar year:

1. monthly totals (gallons) of compliant and noncompliant material used based on the records required by Section H.4,

2. annual totals (gallons) based on each of the coating’s

, solvent’s , and stripper’s monthly data,

3. if claiming the Rule 337.B.1 exemption, annua l totals (gallons) of non-complying coatings for each separate formulation and all formulations, per Section H.7.b, and

4. if permitted, name and address of the company or agency, and the Permit to Operate number that the surface coating equipment is subject to.

M. Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solvent cleaning machine shall comply with the applicable provisions of Rule 321, Solvent Cleaning Machines and Solvent Cleaning.

Click here to return to the list of Appendices in the Staff Report. Comment [A139]: The annual report provision

was relocated from Section H.4 to a stand -alone section per an Industry suggestion.

Comment [A140]: Added to clarify that Rule 321 provisions apply to solvent cleaning machines when used in conjunction with surface coating of aerospace vehicles and com ponents.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

– PARs 330, 337, 349, & 353 Page F-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 1 April 27, 1993[ date of amended rule adoption ] Appendix F Santa Barbara County Annotated Proposed Amended Rule 349, Polyester Resin Operations

RULE 349. POLYESTER RESIN OPERATIONS. (Adopted 4/27/1993 , revised [ date of amended rule adoption ] )

A. Applicability

This rule shall apply to any person owning or operating any all commercial and or industrial polyester resin operation s

.

B. Exemptions

1. Section D.1

, shall not apply to the addition or use of styrene

, provided the volume of styrene used is less than 50 gallons per calendar year per stationary source . A ny person claiming this exemption shall maintain monthly styrene usage records of the total volume (gallons) of styrene used per calendar year consistent with Sections F.6 and make them available to the District for review upon request

. At a minimum, when using compliant materials, the records shall be kept on a monthly basis; and when using noncompliant materials, the records shall be kept on a daily

basis.

2. This rule shall not apply to any cleaning performed with a solvent (including emulsions) that contains two percent by weight or less of each of the following:

a. Reactive organic compounds, and

b. Toxic air contaminants (as determined by ge neric solvent data, solvent manufacturer’s composition data or by a gas chromatography test and a mass spectrometry test).

c. Any person claiming this exemption shall maintain the records specified in Sections F.1.a

and F.1.f in a manner consistent with Section F.7 and make them available for review.

3. This rule shall not apply to polyester resin operations performed with polyester resin materials that contain no reactive organic compounds.

4. Section H shall not apply to any of the following:

a. Cleaning of semiconductor and micr oelectromechanical devices undergoing manufacturing processes involving thin film deposition, vacuum deposition, dry etching, or metal lift-off operations; including any maintenance activities associated with such operations;

b. Cleaning of electronic components;

c. Cleaning of encasements, including decoy shells or box casings

, for electronic components that have a total surface area that is less than 2 square feet;

d. Cleaning of parts, subassemblies, or asse mblies that are exposed to strong oxidizers or reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine);

e. Cleaning of transparencies, polycarbonate, or glass substrates; Comment [A141]: Monthly records will: 1. Substantiate the exemption during the calendar year, and. 2. Alert sources when they are encroaching on the 50 gal/year threshold.

Comment [A142]: The daily recordkeeping provision was added for consistency with the EPA “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.”

Comment [A143]: Essentially the same as the Rule 321.B.1 exemption.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-2 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 2 April 27, 1993[ date of amended rule adoption ] f. Cleaning of solar cells, coated optics, la ser hardware, scientific instruments, highprecision optics, telescopes, avionic equipment, microscopes, and military fluid systems;

g. Cleaning or stripping of coating overspray from personal protective equipment;

h. Cleaning of space vehicles.

5. Section H shall not apply to polyester resin oper ations production or rework of the following products, provided the solvents used contain 200 grams of reactive organic compound per liter of material or less or have a reactive organic compound composite partial pressure of 45 millimeter of mercury at 20 degrees Celsius or less:

a. Satellites, satellite comp onents, aerospace vehicles, aerospace vehicle components, aerospace vehicle payloads, or aeros pace vehicle payload components.

6. Section H shall not apply to polyester resin opera tions production or rework of products used in any laboratory tests or analyses, including qualit y assurance or quality control applications, bench scale projects, or short-term (less than 2 years) re search and development projects. To qualify for this exemption, the following records shall be maintained:

a. A list of all solvents used, which at a minimum includes the manufacturer's identification and the reactive organic compound content of each solvent.

b. For each short-term research and developmen t project, the project description, date it commenced, and date it concluded.

c. Such records shall be retained in accordance with the provisions of Section F.7.

7. Section H shall not apply to cleaning or stripp ing of polyester resin material from personal protective equipment.

C. Definitions

See Rule 102, Definitions, for definitions not limited to this rule

. For the purposes of this Rr ule, the following definitions shall apply:

“Aerospace Vehicle or Component” means any fabricated part, processed part, assembly of parts, or completed unit of any aircraft including but not limited to airplanes, helicopters, missiles, rockets, and space vehicles includes satellites.

“Associated Solvent” means any solvent used in a solvent cleaning machine or for solvent cleaning performed in association with a polyester resin operation

.

“ Atomized Resin Application ” means any resin application technology in which the resin leaves the application equipment and breaks into droplets or an ae rosol as it travels from the application equipment to the surface of the part. Atomized resin application includes, but is not limited to, resin spray guns and resin chopper spray guns.

“Bench Scale Project” means a project (other than at a research and development facility) that is operated on a small scale, such as one capable of being located on a laboratory bench top.

1. “ Catalyst ” is a means any substance added to the resin to initiate polymerization.

2. “ Cleaning Materials ” include but are not limited to, materials used for cleaning hands, tools, molds, application equipment, and work area. Comment [A144]: Our protocol is to change the

lead-in sentences in this manner.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-3 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 3 April 27, 1993[ date of amended rule adoption ] “ Clear Gel Coat ” means any gel coat that is clear or translucen t so that underlying colors are visible. Clear gel coat is used to manufacture parts for sale. Clear gel coat do not include tooling gel coat used to build or repair molds.

“Compliant Material” means any polyester resin material that complies with the 1) applicable monomer content limits in Section D.1.a, D.1.b, or D.1.c, or 2) the D.1.d emission limit of grams per square meter of exposed surface area during resin polymerization; or any solvent that complies with the reactive organic compound content limit in Section H.

3. “ Closed Mold System ” is a means any method of forming objects from polyester resins by placing the polyester resin material in a confining mo ld cavity and applying pressure and/or heat.

“Control” means the reduction, by destruction or removal, of the amount of affected pollutants in a gas stream prior to discharge to the atmosphere.

4. “ Control System ” includes a control device and a collection system means any combination of pollutant capture system(s) and control device(s) used to reduce discharg e to the atmosphere of reactive organic compound or toxic air contaminant emissions generated by a regulated operation

.

“Corrosion -Resistant R esin” means any polyester resin material used to make products for corrosion resistant applications such as, but not limited to, tool ing, fuel or chemical tanks, boat hulls, pools, and outdoor spas.

5. “ Cross-Linking ” is the means any chemical process of chemically bonding two or more polymer chains together.

6. “ Cure ” means to polymerize, i.e., to transform from a liquid to a solid or semi-solid state to achieve desired product physical properties, including hardness.

7. “ Fiberglass ” is means a fiber made from glass and similar in appearance to wool or cotton fiber.

“ Filler ” means any finely divided inert (non-ROC) material that is added to the resin to enhance its mechanical properties and extend its volume. Fillers in clude, but are not limited to, silica, carbon black, talc, mica and calcium carbonate.

“ Fire Retardant Resin ” means any polyester resin material used to make products that are resistant to

flame or fire.

“ Fluid Impingement Technology ” means any spray gun that produces an expanding nonmisting curtain of liquid by the impingement of low-pres sure uninterrupted liquid streams.

8. “ Gel Coat ” is means a polyester resin topcoat that provides cosmetic enhancement and improves resistance to degradation from exposure to the environment.

9. Grams of ROC per liter of material is the weight of ROC per volume of material and can be calculated by the following equation:



### ( W

s 

### ̶ W

w 

### ̶ W

es 

### ) Grams of ROC per liter of material =

V

m

Where:

W

s = weight of volatile compounds in grams

W

w = weight of water in grams

W

es = weight of exempt compounds in grams Comment [A145]: This term has been slightly

modified and moved to Rule 102.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-4 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 4 April 27, 1993[ date of amended rule adoption ] V

m = volume of material in liters

“ High-Strength Resin ” means any polyester resin material with a casting tensile strength of 10,000 pounds per square inch or more, used to manufacture high performance products.

10. High Volume-Low Pressure means spray equipment used to apply coatings by means of a high volume of air delivered at pressures between 0.1 and 10 psi air pressure.

11. “ Inhibitor ” is a means any substance used to slow down or prevent a chemical reaction.

“ Lamination Resins ” means any orthophthalate, isophthalate and dicyclopentadiene resins used in composite system consisting of layers of reinforcement fibers and resins.

12. Low-ROC Emissions Resin Systems are polyester resin materials which contain vapor suppressants to reduce monomer evaporation loss.

“Maintenance Cleaning” means a solvent cleaning operation or a ctivity carried out to keep clean general work areas where manufacturing or repair activity is performed, to clean tools, machinery, molds, forms, jigs, and equipment. This definition does not include the cleaning of adhesive, coating, or ink application equipment.

“Marble or Cultured Resins” means any orthophthalate and modified acrylic isophthalate resins, which are designed for the fabrication of ca st products, such as vanities.

“ Marble Resins ” means any orthophthalate and modified acrylic isophthalate resins used for the fabrication of cast products.

“ Mold ” means any cavity or surface into or on which g el coat, resin, and fibers are placed and from which finished fiberglass parts take their form.

13. “ Monomer ” is an means any organic compound that combines with itself, or other similar compounds to become a cured thermosetting resin (e.g., styrene)

.

“ Non-Atomized Resin Application ” means any application technology in which the resin is not broken into droplets or an aerosol as it travels from the application equipment to the surface of the part. Nonatomized resin application technology includes, bu t are not limited to, non-atomizing spray guns, flowcoaters, chopper flowcoaters, pressure fed resin rollers, resin impregnators, or fluid impingement technology.

“Noncompliant Material” means any polyester resin material that does not comply with the 1) applicable monomer content limits in Section D.1.a, D.1.b, or D.1. c, or 2) the D.1.d emission limit of grams per square meter of exposed surface area during resin polymer ization; or any solvent that does not comply with the reactive organic compound content limit in Section H.

“ Open Molding Resin and Gel Coat Process ” means any process in which the reinforcing fibers and resin are placed in the mold and are open to the surr ounding air while the reinforcing fibers are saturated with resin. For the purpose of this rule, open mo lding includes operations in which a vacuum bag or similar cover is used to compress the uncured laminate to remove bubbles or excess resin, or to achieve a

bond between core material and a laminate.

“ Pigmented Gel Coat ” means any opaque gel coat used to manufa cture parts for sale. Pigmented gel coat does not include tooling gel coat used to build or repair molds.

14. “ Polyester ” is a complex polymeric ester containing difunctional acids and alcohols dissolved in a

monomer. Comment [A146]: Replaced by the term “high volume low pressure spraying equipment” and

relocated it to Rule 102.

Comment [A147]: Added for ease of understanding that styrene is a monomer.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-5 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 5 April 27, 1993[ date of amended rule adoption ] 15. “ Polyester Resin Materials ” include, but are not limited to, unsaturated polyester resins such as isophthalic, orthophthalic, halogenated, bi s phenol

- A, vinyl

- ester, or furan resins; cross

- linking agents; catalysts, gel coats, inhibitors, accelerators, promoters, and any other ROC reactive organic compound containing materials in polyester resin operations.

16. “ Polyester Resin Operations ” are means those methods used for the production or rework of products by mixing, pouring, hand lay-up, impregnati ng, injecting, forming, winding, spraying, and/or curing unsaturated polyester resin materials with fibe rglass, fillers, or any ot her reinforcement materials

and associated cleanup solvent cleaning

.

17. “ Polymer ” is a means any chemical compound comprised of a large number of chemical units and which is formed by the chemical linking of monomers.

“Primer Gel Coat” means any gel coat used to coat the surfa ce of composite parts prior to top-coat painting in the automotive, aerospace, marine and home building industries.

18. “ Repair ” is that part of the fabrication process that requires the addition of polyester resin material to portions of a previously fabricated product in order to mend minor structural damagemeans the process of returning a damaged object or an object not operating properly to good condition

.

19. “ Resin ” is means any of a class of organic polymers of natural or synthetic origin used in reinforced products to surround and hold fibers, and is solid or semi-solid in the cured state.

“ Solid Surface Resins ” means any resin used without gel coats to fabricate homogenous solid surface products.

“Solvent” means any liquid containing any reactive organic compound or any toxic air contaminant, which is used as a diluent, thinner, dissolver, viscosity redu cer, cleaning agent, drying agent, preservative, or other

similar uses.

“Solvent Cleaning” means any activity, operation, or process (including, but not limited to, surface preparation, cleanup, or wipe cleaning) performed outsid e of a solvent cleaning machine, that uses solvent to remove uncured adhesives, uncured coatings, uncu red inks, uncured polyester resin material, uncured sealant, or other contaminants, including, but not limite d to, dirt, soil, oil, lubricants, coolants, moisture, fingerprints, and grease, from parts, products, tools, machinery, application equipment, and general work areas. Cleaning spray equipment used for the application of coating, adhesive, ink, polyester resin material,

or sealant is also considered to be solvent clea ning irrespective of the spray material being cured.

“Solvent Cleaning Machine” means any device or piece of equipment that uses solvent liquid or vapor to remove soils, moisture, or other contaminants from the surfaces of materials. Types of solvent cleaning machines include, but are not limited to, batch cold , batch vapor, in-line cold, in-line vapor, remote reservoir, and gas-path solvent cleaners. Buckets, p ails, and beakers with capacities of 3.785 liters (1.00 gallon) or less are not considered solvent cleaning ma chines. However, the use of such a container or similar containers (e.g., hand-held spray bottles) wi th a liquid solvent for cleaning is considered to be solvent cleaning. Any device or piece of equipment used exclusively for stripping shall not be considered to be a solvent cleaning machine.

“ Specialty Gel Coat ” means any gel coat which is used in co njunction with fire retardant, corrosion resistant, or high-strength materials.

20. “ Specialty Resin ” is means any halogenated, furan, bi s phenol A

, vinyl ester, or isophthalic resin used to make products for exposure to one or more of the following extreme environmental conditions: acute or chronic exposure to corrosive, caustic, acidic

, agents, or flame.

“ Tooling Resin ” means any resins used to buil d or repair molds (also known as tools) or prototypes (also known as plugs) from which the molds will be made. Comment [A148]: Solvent, solvent cleaning

, and solvent cleaning machine are the same

definitions found in Rule 321. Solvent includes any liquid containing any toxic air contaminant.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-6 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 6 April 27, 1993[ date of amended rule adoption ] “ Tooling Gel Coat ” means any gel coat used to build or repair molds (also known as tools) or prototypes (also known as plugs) from which the molds will be made.

21. Touch-Up is that portion of the fabrication process that is necessary to cover minor imperfections.

“ Tub/Shower Resin ” means any dicyclopentadiene resin, along with orthophthalate and isophthalate resins, used to fabricate bathware products.

22. “ Vapor Suppressant ” is a means any substance added to resin to minimize the outward diffusion of monomer vapor into the atmosphere.

23. “ Waste Materials ” include, but are not limited to any pa per or cloth used for cleaning operations, waste resins, and any spent cleaning materials.

D. Requirements

1. Process and Control

Any No person shall operatingoperate a polyester resin operation unless the operation shall comply complies with one or more of the following

, as applicable.

a. Before [ 24 months after the date of amended rule adoption ], Use use polyester resin material with monomer content of no more than 35 percent by weight as applied and as determined by the manufacturer's specification. This requirement shall not apply to gel

coats

, provided the monomer content does not exceed 45 percent by weight for pigmented gel coats and does not exceed 50 percent by weight for clear gel coats . On and after [ 24 months after the date of amended rule adoption ], use materials that comply

with the limits in Table 349-1 ; or,

b. Before [ 24 months after the date of amended rule adoption ], Use use specialty resin with a monomer content of no more than 50 percent by weight as applied and as determined by the manufacturer's specification . On and after [ 24 months after the date of amended rule adoption ], use materials that comply with the limits in Table 349-1 ; or,

c. On and after [ 24 months after the date of amended rule adoption ], use polyester resin material that comply with the limits shown in Table 349-1 below when using the open molding resin and gel coat process; or

Table 349-1: Monomer Content Limits for Polyester Resin Materials

Polyester Resin Material As-Applied Monomer Content Limits (Percentage, by Weight)

Clear Gel Coat

For Marble Resins 40%

All Other Resins 44% Pigmented Gel Coat

White and Off White 30%

Non-White 37%

Primer 28% Specialty Gel Coat 28% Tooling Gel Coat 40% General Purpose Resin

Lamination Resins 31% or 35%, as supplied, with no fillers

Marble or Cultured 10% or Comment [A149]: The Air Resources Board suggested we lower the monomer content limits and emission limit for vapor suppressed resins. They also suggested we increase the add -on control equipment efficiency to 90%. The District is proposing a 24 -month phase- in period for these new requirements.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-7 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 7 April 27, 1993[ date of amended rule adoption ] Polyester Resin Material As-Applied Monomer Content Limits (Percentage, by Weight)

Resins 32%, as supplied, with no fillers

Solid Surface Resins 17%

Tub/Shower Resins 24% or 35%, as supplied, with no fillers Specialty Resin

Corrosion Resistant

Resin 48%

Fire Retardant Resin 38% High Strength Resin 40% Tooling Resin Atomized (spray) 30%

Non-atomized 39%

All Other Resin 35%

d. Before [ 24 months after the date of amended rule adoption ], Useuse a resin containing a vapor suppressant, such that the weight loss from ROC reactive organic compound emissions does not exceed 60 grams per square meter of exposed surface area during resin polymerization ;

. On and after [ 24 months after the date of amended rule adoption ], use a resin containing a vapor suppressant, such that the weight loss from reactive organic compound emissions does not exceed 50 grams per square meter of exposed surface area during resin polymerization. The “ grams per square meter of exposed surface area during resin polymerization ” shall be as determined by the test method specified in Section E. 12 ; or,

de . Use a closed mold system; or,

ef . Install and operate an add-on emission control system , which is designed and operated in a manner that reduce uncontrolled emissions by at least 85 percent. provided all of the applicable requirements below are met. Any person installing such control system shall obtain an Authority to Construct from the District prior to installation.

i. Before [ 24 months after the date of amended rule adoption ], the overall efficiency (the capture efficiency multiplied by the control device efficiency) of the total system shall be at least 85 percent, by weight. On and after [ 24 months after the date of amended rule adoption ] the overall efficiency shall be at least 90 percent, by weight. Alternatively, the control device reactive organic compound exhaust concentration shall not exceed 10 parts per million by volume as propane or other limit appr oved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer.

ii. Combustion temperature shall be continuously monitored when operating a

thermal incinerator.

iii. Inlet and exhaust gas temperatures shall be continuously monitored when operating a catalytic incinerator.

iv. Control device efficiency shall be continuously monitored when operating a

carbon adsorber or a control device other than a thermal or catalytic incinerator.

v. Compliance through the use of an emission control system shall not result in affected pollutant emissions in excess of the affected pollutant emissions that would result from compliance with Sections D.1.a - D.1.d or H. Comment [A150]: Subsections i - iv mirror Rule 353.I provisions.

Comment [A151]: Similar to Rule 321.N.6. ( Reactive organic compound changed to affected pollutant to include TACs.)STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-8 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 8 April 27, 1993[ date of amended rule adoption ] 2. Spray Application Methods

Any No person operating shall apply a polyester resin operation shall, when applying polyester

resin materials by in a spraying operation , unless the application is performed with equipment operating according to the manufacturers operatin g guidelines. use only In addition, the application method employed shall be one of the following:

a. aA irless, or

b. aA ir-assisted airless, or

c. hH igh volume

- low pressure spraying equipment , or

d. eE lectrostatic spray equipment , or

e. Any other spray application method as approved by the Control Officer , the Air Resources Board, and the Environmental Protection Agency. and operated in accordance

with the manufacturer's recommendations.

3. Storage and DisposalGeneral Operating

A person operating a polyester resin operation shall use closed containers to store all polyester resin materials, cleaning materials, and any unus ed ROC-containing materials except when accessed for use.Any person who owns or operates any polyester resin operation equipment or uses any associated solvent subject to this rule shall meet the following requirements:

a. All polyester resin materials and cleaning m aterials, used or unused, shall be stored and disposed of in nonabsorbent and nonleaking containers equipped with tight-fitting covers. All covers shall be in place unless adding material to or removing material from the containers, the containers are empty, or doing maintenance/inspection of the containers.

b. All application equipment, ventilation syst em, and emission control equipment shall be installed, operated, and maintained consiste nt with the manufacturer’s specifications.

c. Waste solvent, waste solvent residues, and any other waste material that contains reactive organic compounds shall be disposed of by one of the following methods:

i. A commercial waste solvent reclamation service licensed by the State of

California.

ii. At a facility that is federally or state li censed to treat, store or dispose of such

waste.

iii. Recycling in conformance with Section 25143.2 of the California Health and Safety Code.

d. All covers, valves, drain plugs, and other closure devices designed to reduce polyester resin material and cleaning material evaporation shall not be removed or opened except to process work or to perform monitoring, inspections, maintenance, or repairs that require the removal of the covers or other closure devices.

e. Any spills of polyester resin materials or cleaning materials shall be wiped up immediately and the used absorbent material (e.g., cloth, paper, sand, sawdust, etc.) shall

be stored in closed contain ers that are handled in accordance with Section D.3.a.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-9 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 9 April 27, 1993[ date of amended rule adoption ] f. The handling and transfer of polyester resin materials and cleaning solvents to or from enclosed systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or spent coatings and c leaning solvents shall be conducted in such a manner to minimize spills.

g. Containers used to store polyester resin material, solvent, or any waste material that contains reactive organic compounds subject to this rule shall be marked or clearly labeled indicating the name of the material they contain.

E. Compliance Provisions and Test Methods

1. Compliance with Section D.1.a or D.1.b Polyester resin material monomer contents shall be

determined measured using ASTM method D2369- 8195 , “Standard Test Method for Volatile Content of Coatings,” ASTM International . Material tested shall be non-catalyzed.

2. Compliance with Section D.1.c The weight loss from reactive organic compound emissions shall

be determined measured by laboratory static test s
, “Static Method for Determination of Volatile Emissions from Polyester and Vinyl Ester Resins,” as described in Attachment A.

3. Capture efficiency determinations The capture efficiency for reactive organic compound emissions required in Section D.1.d shall be based on criteria set forth by EPA in 40 CFR 52.741 determined by verifying the use of a Permanent Total Enclosure and 100 percent capture efficiency as defined by Environmental Protection Agency Method 204, “ Criteria for and Verification of a Permanent or Temporary Total Enclosure.” Alternatively, if an Environmental Protection Agency Method 204 defined Permanent Total Enclosure is not employed, capture efficiency shall be determined using a minimum of three sampling runs subject to data quality criteria presented in the Environmental Protection Agency technical guidance document “ Guidelines for Determining Capture Ef ficiency, January 9, 1995.” Individual capture efficiency test runs subject to the Environmental Protection Agency technical guidelines shall be determined by:

a. The Temporary Total Enclosure approach of Environmental Protection Agency Methods 204 through 204F; or

b. The South Coast Air Quality Management District “ Protocol for Determination of Volatile Organic Compounds (VOC) Capture Efficiency, ” May 1995.

4. Control efficiency determinations The control de vice efficiency for reactive organic compound emissions required in Section D.1.d shall be made using EPA Method 25 or 25A. Gas flow rate measurements in pipes or small ducts shall be made using EPA Method 2A. determined by Environmental Protection Agency Methods 25, 25A, the South Coast Air Quality Management District Method 25.1, “ Determination of Total Gaseous Non-Methane Organic Emissions as Carbon,” February 1991, or the South Coast Air Quality Management District Method 25.3,

“ Determination of Low Concentration Non-Methane Non-Ethane Organic Compound Emissions from Clean Fueled Combustion Sources,” March 2000, as applicable . Environmental Protection Agency Test Method 18 or Air Resources Board Method 422, “ Exempt Halogenated VOCs in

Gases ,” September 12, 1990, shall be used to deter mine emissions of exempt compounds.

5. Solvent reactive organic compound content shall be measured by the Environmental Protection Agency Reference Method 24, its constituent methods, or an equivalent method approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer. The determination of exempt compounds shall be performed in accordance with ASTM D 4457-1991,

“ Standard Test Method for Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings by Direct Injection into a Gas Chromatograph, ” ASTM International. Alternatively, determination of exempt compounds may be performed in accordance with the South Coast Air Quality Management District Method 303- 91, “Determination of Exempt Compounds,” August 1996. The reactive organic compound content of materials containing 50 grams of reactive Comment [A152]: The housekeeping provisions are similar to requirements found in Rule 321.D.

Comment [A153]: EPA recommended that the

District model t he provisions on SC Rule 1122(h)(7)(A) text.

Comment [A154]: EPA suggested that this provision mirror the SC Rule 1122(h)(7)(B) text.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-10 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 10 April 27, 1993[ date of amended rule adoption ] organic compound per liter or less shall be determined by the South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer.

6. The capture efficiency for toxic air contam inant emissions that are not reactive organic compounds shall be determined by using the meth ods described in Section E.3 modified in a manner approved by the Control Officer to quantify the mass of liquid or gaseous reactive organic compounds and/or toxic air contaminants.

7. The control device efficiency for toxic air cont aminant emissions that are not reactive organic compounds shall be determined using:

a. an Environmental Protection Agency approved test method or methods, or

b. in the case where there is no Environmental Protection Agency approved test method, a Control Officer approved detection method a pplicable for each target toxics specie.

c. the Control Officer may require more than one test method on any emission control device where necessary to demonstrate that the overall efficiency is at least 85 percent by weight in reducing emissions of reactive organic compounds and/or toxic air contaminants. Any technique to convert “parts per million by volume” test method results to either 1) “parts per million by we ight,” or 2) “mass emission rates” (e.g., pounds per hour) shall first be approved by th e Control Officer and, if such approval is not provided, then the technique shall not be used to show compliance with this rule.

8. Emissions of reactive organic compounds from th e exhaust of an emission control system shall be measured by the Environmental Protection Agency Method 25, in combination with Environmental Protection Agency Method 18 or the California Air Resources Board Method 422, “Exempt Halogenated VOCs in Gases,” S eptember 12, 1990 (to determine emissions of exempt compounds).

9. When more than one test method or set of test methods are specified for any testing, a test result showing an exceedance of any limit of this rule shall constitute a rule violation.

10. The Environmental Protection Agency test methods in effect on [ date of amended rule adoption ] shall be the test methods used to meet the requirements of this rule.

F. Recordkeeping

Any person subject to this rule shall comply with the following requirements :. Any owner or operator of any stationary source comprised of more than one facility may comply with the following requirements on a facility basis.

1. A person shall mM aintain a current list file of resins and cleaning all reactive organic compoundcontaining materials in use at the stationary source subject to this rule. which The file shall provide s all of the data necessary to evaluate compliance and shall include, including the following information, as applicable:

a. the type of resin, catalyst, and cleaning materials used (e.g., brand name, stock identification number).;

b. the weight percent of ROC in each of the polyester resin materials, and the grams of ROC per liter for the cleaning materials.if applying polyester resin materials in spraying operations, indicate the spray application method us ed (e.g., airless, air-assisted airless, etc.); Comment [A155]: EPA recommended referring

to SC Method 313 for d etermining ROC content of materials containing < 50 g/l.

Comment [A156]: Similar to the Rule 321.P.3 requirements.

Comment [A157]: Essentially the same as Rule 321.P.4 provisions.

Comment [A158]: Added per the EPA recommendation in the Technical Support Document for SJV Rule 4605 (June 2009).

Comment [A159]: Our protocol is to specify requirements are on a stationary source basis.

Comment [A160]: Essentially the same text

found in Rule 353.O.1.

Comment [A161]: This data is now required by §F.1.e.

Comment [A162]: Similar to the recordkeeping provisions in PARs 330, 337, and 353.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-11 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 11 April 27, 1993[ date of amended rule adoption ] c. for approved vapor suppressed resins, the weight loss (grams per square meter) during resin polymerization, the monomer percentage, and the gel time for each resin .;

d. if mixing solvents, specific solvent mixing data (e.g., component volumes or weights) of each component for each batch sufficient to determine the mixture’s reactive organic compound content;

e. the actual as applied reactive organic compoun d content of the solvent used and, when not using a closed mold system, the correspond ing monomer content limits from Sections D.1.a, b, or c, and the actual as applied monomer contents; or if complying using a vapor suppressant, the actual polyester or vinyl ester resin weight loss rate of the materials used; and

f. current polyester resin material and solvent manufacturer specification sheets, Material Safety Data Sheets, product data sheets, or air quality data sheets, which list the reactive organic compound content of each material in use at the stationary source subject to this rule. Compliance with this provision may be done by ensuring the manufacturer’s specifications are listed on the product container.

2. Maintain records for eac h reactive organic compound-containing material purchased for use at the stationary source. The records shall include, but not be limited to, the following:

a. material name and manufacturer identification (e.g., brand name, stock identification number); and

b. material type (e.g., polyester resin material type as specified in Table 349-1, cleanup solvent, etc.).

3. Maintain records of the disposal method each time waste solvent, or waste solvent residue, or other waste material that contain reactive organic compounds is removed from the stationary source for disposal.

4. For each material listed in response to Section F. 1.a, maintain, at a minimum, on a monthly basis for compliant material and on a daily basis for noncompliant material, a record of the following:

a. volume used (gallons per day, gallons per month);

b. polyester resin material as-applied weight percent of monomer and the cleaning material reactive organic compound content (grams per liter or pounds per gallon);

c. polyester resin material reactive organic comp ound emission factors (pounds of reactive organic compounds per pounds of monomer used or pounds of reactive organic compounds per gallon); and

d. resulting reactive organic compound emissions (pounds per day, pounds per month).

25. Any person using add-on For any stationary source that uses emission control equipment to meet the requirements of this rule , shall maintain daily records of key operating parameter s values and maintenance procedures that verify demonstratethat the control equipment was operating properly for each day of operation continuous operation and compliance of the emission control system during periods of emission producing activities shall be maintained. These parameters shall include, but not be limited to:

a. Hours of operation; Comment [A163]: The daily recordkeeping provision was added for consistency with the EPA “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.”STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-12 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 12 April 27, 1993[ date of amended rule adoption ] b. All maintenance work that requires the emission control system to be shut down; and

c. All information needed to demonstrate continuous compliance with Section D.1.f, such as temperatures, pressures, and/or flow rates.

. 6. Any person claiming an exemption under Section B.1 shall maintain, at a minimum, monthly records for compliant material an d daily records for noncompliant material of styrene volumes used in gallons per day and/or gallons per month to support the claim of exemption.

37

. Such records shall be retained for the previous 24 month period and be available to the District upon request.Any records required to be maintained pursuant to this rule shall be kept on site for at least 2 years unless a longer retention period is otherwise required by state or federal regulation(s). Such records shall be kept on site and be readily available for inspection and review by the District.

G. Compliance Schedule

A person who is subject to the requirements of this d etermination shall be in compliance by April 27, 1994.

Any person who owns or operates any polyester resi n operation equipment subject to this rule shall meet the following compliance schedule:

1. By [ 30 days from the date of amended rule adoption ], comply with Section D.3, General Operating.

2. By [ six months from the date of amended rule adoption ], comply with the recordkeeping provisions in the following Sections:

a. F.1.d - mixing data,

b. F.1.e - solvent reactive organic compound content data, polyester resin material monomer contents (when not using a closed mold system), and/or actual weight loss rate data (when using a vapor suppressant),

c. F.1.f - manufacturer specification sheets, Material Safety Data Sheets, air quality data sheets, or manufacturer specification listings on product container,

d. F.2 - purchase records,

e. F.3 - waste disposal records, and

f. F.4 - polyester resin material reactive organic compound emission factor records and daily records for noncompliant materials.

3. By [ 12 months from the date of amended rule adoption ], comply with the Section H and Section J requirements.

4. By [ 24 months from the date of amended rule adoption ], comply with any applicable Section D provisions that have a phased-in effective date.

5. By [ date of amended rule adoption ], comply with all other provisions of this rule. Comment [A164]: Subsections a - c are from

Rule 321.R.1.c.

Comment [A165]: The daily recordkeeping provision was added for consistency with the EPA “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.”

Comment [A166]: The compliance schedule provision was expanded in response to a request from Industry.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-13 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 349 - 13 April 27, 1993[ date of amended rule adoption ] H. Requirements

– Solvent Cleaning

Section H requirements apply to any person performi ng solvent cleaning associated with polyester resin operations, including, but not limited to, use of wipe cl eaning cloths, hand-held sp ray bottles, squirt bottles, aerosol products, and the cleaning of application equipm ent. The following requirements become effective
[ one year from the date of amended rule adoption ] and are in addition to the general operating requirements specified in Section D.3.

1. Solvent Requirements. Except when using an emission control system that meets the requirements of Section D.1.e, no person shall use any solvent to perform solvent cleaning which exceeds the applicable grams of reactive organic compound per liter of material limit specified in

Table 349-2.

Table 349-2: Reactive Organic Compound Content Limits for Solvent Cleaning

SOLVENT CLEANING ACTIVITY ROC Limit, grams of ROC per liter of material (pounds of ROC per gallon)

(a) Product Cleaning During Manufacturing Process or Surface Preparation for Coating Application 25 (0.21)

(b) Repair and Maintenance Cleaning 25 (0.21) (c) Cleaning of Polyester Resin Application Equipment 25 (0.21)

I. Reporting Requirements

Submittal of an annual report to the District is required if a person holds a permit for equipment subject to the requirements of this rule. The annual report shall be due March 1 and it shall contain the following information for the previous calendar year:

1. monthly totals (gallons) of co mpliant and noncompliant material used based on the records required by Section F.4,

2. annual totals (gallons) based on each of the polyester resin materials ’ and cleaning materials ’ monthly data,

3. if claiming the Rule 349.B.1 exemption, monthly totals of styrene (gallons) used per Section F.6 and the yearly total amount (gallons) of styrene used, and

4. name and address of the company or agency an d the Permit to Operate number that the polyester resin operation is subject to.

J. Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solvent cleaning machine shall comply with the applicable provisions of Rule 321, Solvent Cleaning Machines and Solvent Cleaning. Comment [A167]: Section H stems from similar solvent cleaning provisions in Rule 321.M.

Comment [A168]: Both ARB and EPA recommend a 25 g/l limit on the solvent's ROC

content.

Comment [A169]: The annual report provision

was relocated from Section F.5 to a stand-alone section per an Industry suggestion.

Comment [A170]: Added to clarify that Rule 321 provisions apply to solvent cleaning machines when used in conjunction with polyester resin operations.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-14 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 Attachment A - 1 April 27, 1993[ date of amended rule adoption ] ATTACHMENT A

STATIC METHOD FOR DETERMINATION OF VOLATILE EMISSIONS FROM

POLYESTER AND VINYL ESTER RESINS

1. PURPOSE

1.1 This test is designed for the determination of volatile organic compound emissions of polyester and vinyl ester resins as received from the manufacturer, according to requirements of California's South Coast Air Quality Management District (SCAQMD) proposed Rule 1162 amendment published July 17, 1990Method 309-91, Determination of Static Volatile Emissions, revised February 1993

.

1.2 This test allows fabricators using polyester and vinyl ester resins to monitor volatile organic compound emissions (principally styrene monomer) from resins used in the fabrication process. The results are to be reported as volatile organic compound losses in grams per square meter (gm/m 2 ).

2. METHOD

The weight of a one gallon can lid filled with 100 gm grams of resin is accurately measured over a period of time. The measurement is made on resi n catalyzed with peroxide initiators to determine weight losses attributed to monomer and other volatile organic compound emissions.

3. EQUIPMENT REQUIREMENTS

3.1 Controlled environment at 25.0 C degrees Celsius and humidity of 50 % R.H percent relative humidity . If controlled environment is not available , report condition under which measurements

are made.

3.2 Balance with an accuracy of 0.01 gmgram

.

3.3 Draft free enclosure for balance. This can be achieved by placing the balance in a four sided enclosure that extends a minimum of eight inches above the top of the balance.

3.4 Gallon can lid with deep form sufficient to contain 100 gm grams of resin, having a normal

diameter of 14.5 cmcentimeters

.

3.5 Certified or calibrated thermometer capable of measurements accurate to 1 degree CCelsius

.

3.6 Constant temperature bath controlled at 25 °C degrees Celsius to adjust resin temperature to

25 °C degrees Celsius

.

3.7 Timer - capable of recording time to 0.1 min ute

.

3.8 Paper clip - bent to approximately 90 ° degree angle.

3.9 Syringe or pipette accurate to 0.1 ml milliliter for peroxide catalyst addition. Comment [A171]: Attachment A changes align the procedures to this text method.STAFF REPORT

– PARs 330, 337, 349, & 353 Page F-15 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 Attachment A - 2 April 27, 1993[ date of amended rule adoption ] 4. PROCEDURE

4.1 Weigh out 200 gm grams of prepromoted resin into a suitable dry and clean container. Wax cups

should not be used for this test.

4.2 Cover container and place in constant temperature bath and adjust resin temperature to 25 °C degrees Celsius

.

4.3 Place balance in draft free enclosure.

4.4 Clean gallon lid with solvent, wipe dry and air dry and measure diameter to the nearest 0.1

cmcentimeter

.

4.5 Place gallon can lid on an inverted paper or plas tic cup mounted on the balance pan. Position bent paper clip in the center of the gallon can lid. Record TARE WEIGHT to 0.01 gmgram

.

4.6 Take container with resin from water bath and add appropriate volumetric or weight measure of catalyst using syringe or pipette. Start timer. (continued)

4.7 Using stirring rod or thermometer, mix in catalyst for one minute.

4.8 Pour 100.0 +/- plus or minus 0.5 gm gram of catalyzed resin into can lid and record weight to +/- plus or minus 0.01 gmgram . This is the INITIAL WEIGHT.

4.9 Using paper clip, determine when resin has hard ened sufficiently to allow resin or lid to be lifted or the gel to be torn

.

4.10 Record this as gel time.

4.11 Allow resin to harden in can lid and reweigh every 15 minutes until concurrent weighing agrees to

within 0 .05 gmgram . Record this as FINAL WEIGHT to +/- plus or minus 0.01 gmgram

.

4.12 Procedure should be repeated until duplicate samples agree to the nearest 5 gm per m 2 grams per

meter 2

.

5. CALCULATION

5.1 Volatile Organic Compound Emissions per Square Meter

( d /2) 2 x 3.14 Area of Gallon Can Lid in m 2

= 10,000 cm 2 / m 2

Area of Sample in Square Meter = (d/2) 2 * 3.14

Where: d = diameter of the gallon can lid in centimeters (cm)

3.14 = value of Pi

cm 2 = square centimeters

m 2 = square meters

Volatile Organic Compound Losses , Grams per Square Meter = INITIAL WEIGHT - FINAL WEIGHT

Area of Sample Gallon Can Lid in Square MetersSTAFF REPORT

– PARs 330, 337, 349, & 353 Page F-16 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 349 Attachment A - 3 April 27, 1993[ date of amended rule adoption ] 5.2 Percent Volatile Organic Compound Emission = INITIAL WEIGHT - FINAL WEIGHT x 100

INITIAL WEIGHT - TARE WEIGHT

6. REPORTING REQUIREMENTS

6.1 Ambient temperature and humidity.

6.2 Resin identification and batch number.

6.3 Initiator system and amounts used.

6.4 Volatile organic compound losses as grams per square meter.

6.5 Percent volatile organic compound emission.

6.6 Gel time under conditions of test.

Click here to return to the list of Appendices in the Staff Report.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-1 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 1 August 19, 1999[ date of amended rule adoption ] Appendix G Santa Barbara County Annotated Proposed Amended Rule 353, Adhesives and Sealants

RULE 353 ADHESIVES AND SEALANTS. (Adopted 8/19/1999 , revised [ date of amended rule adoption ] )

A. Applicability

This rule is applicable to any person who supplies, sells, offers for sale, distributes, or manufactures

, solicits the application of any adhesive product or sealan t product for use within the District, as well as to any person who, or uses , applies, or solicits the use or application of any adhesive s product

, adhesive bonding primers, adhesive primers, sealant s product

, sealant primers, or any other primersor associated solvent within the District, unless otherwise specifically exempted by this rule

.

B. Exemptions

1. The provisions of this rule shall not apply to the following:

a1

. This rule shall not apply to Aa dhesives and associated solvents used in tire repair operations, provided a label on the adhesive used states "For Tire Repair Only."

b2

. This rule shall not apply to Aa dhesives and associated solvents used in the assembly and manufacturing of undersea-based weapon systems.

c3

. Provisions of Sections D, E, G. 1, and H, shall not apply to any Aa dhesive s products

, adhesive bonding primers, adhesive primers, sealants, sealant primers products

, and any associated solventor any other primers bein g tested or evaluated used in any laboratory tests or analyses, including quality assurance or quality control appli cations, bench scale projects, or short-term (less than 2 years) research and development projects, quality assurance, or analytical laboratory, . To qualify for this exemption, provided that the following records shall be are maintained and made available to District personnel for a period of at least five (5) years :

1)a. A list of all such materials used, which at a minimum includes the manufacturer's identification, the product category of the materi al or type of application, and the reactive organic compound content of each material.

2)b. For each short-term research and developm ent project, the project description, date it commenced, and date it concluded.

c. Such records shall be retained in accordance with the provisions of Section O. 46 of this

rule

.

d4

. This rule shall not apply to Ss olvent welding operations and associated cleaning solvents used in the manufacturing of medical devices, such as, but not limited to, catheters, heart valves, blood cardioplegia machines, tracheotomy tubes, bl ood oxygenators, and ca rdiatory reservoirs.

e. Plaque laminating operations where adhesives are used to bond a clear, polyester acetate laminate to wood with lamination equipment installed prior to July 1, 1992. Any person seeking to claim this exemption shall notify the Control Officer in writing that a complying adhesive is not

available. Comment [A172]: Adding or associated solvent extends the applicability to solvent cleaning. This change stems from a commitment in the 2010 C lean

Air Plan.

Comment [A173]: Modeled on the Rule 321.B.8.b exemption.

Comment [A174]: Substantiates that R&D projects are short-term.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-2 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 2 August 19, 1999[ date of amended rule adoption ] f5

. This rule shall not apply to Aa dhesive s product and , adhesive bonding primers, adhesive primers, sealants, sealant primers product, or any other primers c oating operations and associated solvent use regulated by either of that are subject to any of the following District rules , provided the rule has been approved as part of the State Impl ementation Plan by the Environmental Protection Agency

.

1)a. Rule 337, Surface Coating of Aircraft or Aerospace Vehicle s Parts and ProductsComponents

.

2)b. Rule 354, Graphic Arts.

g6

. This rule shall not apply to Aa dhesive s products and , adhesive bonding primers, adhesive primers, sealants, sealant primers products , or any other primers that contain less than 20 grams of reactive organic compound per liter (0.17 pounds of reactive organic compound per gallon) of adhesive or sealant, less water and less exempt compounds, as applied.

h7

. This Except for Section J, the rule shall not apply to Cc yanoacrylate adhesives.

i8

. Except as otherwise specified in Section B.10.c, this rule shall not apply to Aa dhesive s products and , adhesive bonding primers, adhesive primers, sealants, sealant primers products

, or any other primers, which are sold or supplied by the manufacturer or suppliers in containers of 16 fluid

ounces or less.

29

. The provisions of this rule, eE xcept for Section s J, K , (Prohibition of Sales)L, M, O.3, and O.6

, this rule shall not apply if the to any stationary source that has total reactive organic compound

emissions less than 200 pounds per calendar year from adhesive product s , adhesive bonding primers, adhesive primers, sealant product s, associated solvents, and stripperssealant primers, or any other primers. applied at the stationary sour ce are less than 200 pounds per calendar year. Associated solvents and strippers used for operations that are exempt per Sections B.1 - B.4, B.11, and B.13 shall not be included in calculating the total reactive organic compound emissions under this exemption. Any person claiming this exemption shall record and maintain monthly operational and emission records that can substantiate this claimdocument compliance

. At a minimum, when using compliant materials, the records shall be kept on a monthly basis; and when using noncompliant materials, the records shall be ke pt on a daily basis. Further, the records shall be made available to District personnel for a period of at least five (5) years.All Such records kept to substantiate the exemption claim shall be retained in accordance with the provisions of Section

O.6.

310 . The sales prohibition in Sections K.1 and K.2 of this rule shall not apply to:

a. Any supplier or seller of any adhesive product (including aerosol adhesive), adhesive bonding primer, adhesive primer, sealant, or sealant primer product , or any other primer where the supplier or seller:

1) Ships the product outside of Santa Barbara County for use outside of Santa Barbara County.

2) Provides product to a user who has ins talled a District permitted reactive organic compound add-on control device.

b. Any manufacturer of any adhesive product (including aerosol adhesive) or , adhesive bonding primer, adhesive primer, sealant, sealant primer product , or any other primer, if the manufacturer has provided the maximum volatile organic compound content per

Section L of this rule and if: Comment [A175]: The daily recordkeeping provision was added for consistency with the EPA “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.”STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-3 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 3 August 19, 1999[ date of amended rule adoption ] 1) The product was not sold directly to a user or a sales outlet located in Santa Barbara County, or

2) The product was sold to an independent distributor that is not a subsidiary of, or under the direct control of, the manufacturer.

c. The sale of any adhesive product (including aerosol adhesive) or, adhesive bonding primer, adhesive primer, sealant, sealant primer product

, or any other primer, except plastic cement welding adhesives, if:

1) The product is sold in any container(s) having a capacity of 16 fluid ounces or less (net volume) or one pound or less (net weight); and

2) The total net weight or volume of two or more containers packaged together must be equal to or less than one po und or 16 fluid ounces, respectively, to qualify for this exemption.

11. This rule shall not apply to any cleaning performed with a solvent (including emulsions) that contains two percent by weight or less of each of the following:

a. Reactive organic compounds, and

b. Toxic air contaminants (as determined by ge neric solvent data, solvent manufacturer’s composition data or by a gas chromatography test and a mass spectrometry test).

c. Any person claiming this exemption shall maintain the records specified in Sections

O.1.a and O.1.f in a manner consistent with Section O.6 and make them available for

review.

12. This rule shall not apply to adhesive products (including aerosol adhesives) and sealant products subject to the Air Resources Board consumer products regulation found in Title 17 of the California Code of Regulations, section 94507 et seq.

13. Provisions of Sections G.1, H, and R shall not ap ply to solvents and strippers used on any of the following:

a. Cotton swabs when removing cottonseed oil before the cleaning of high-precision optics;

b. Paper gaskets;

c. Clutch assemblies where rubber is bonded to metal by means of an adhesive;

d. Cleaning of semiconductor and micr oelectromechanical devices undergoing manufacturing processes involving thin film deposition, vacuum deposition, dry etching, or metal lift-off operations; including any maintenance activities associated with such operations;

e. Electronic components;

f. Cleaning of encasements, including decoy shells or box casings, for electronic components that have a total surface area that is less than 2 square feet;

g. Parts, subassemblies, or assemblies that ar e exposed to strong oxid izers or reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine);

h. Transparencies, polycarbonate, or glass substrates; Comment [A176]: Essentially the same as the Rule 321.B.1 exemption.

Comment [A177]: Modeled on exemptions found in South Coast AQMD (SC) Rule 1168(j)(13)

and SJV Rule 4653.4.1.7.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-4 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 4 August 19, 1999[ date of amended rule adoption ] i. Solar cells, coated optics, laser hardware, s cientific instruments, high-precision optics, telescopes, microscopes, avionic equipment, and military fluid systems;

j. Personal protective equipment.

C. Definitions

See Rule 102, Definitions, for definitions not limited to this rule. For purposes of this rule, the following definitions shall apply:

“Acrylonitrile -Butadiene- Styrene (ABS) Welding Adhesive” means any adhesive intended by the manufacturer to weld ABS pipe. ABS pipe is made by reacting monomers of acrylonitrile, butadiene, and styrene and is normally identified with an ABS marking.

“Adhesive” means any substance that is used to bond one su rface to another surface by attachment or fused

union.

“Adhesive Primer” means any product intended by the manufactur er to be applied to a substrate, prior to the application of an adhesive, to provide a bonding surface.

“Adhesive Bonding Primer” means an adhesive applied to a surface to improve the bond of subsequent

adhesives and sometimes to inhibit corrosion.

“Adhesive Primer for Plastic ” means a material applied to a plastic substrate before applying an adhesive

in order to obtain better adhesion.

“Adhesive Product” means any adhesive, glue, cement, mastic, adhesive primer, adhesive primer for plastics, and any other adhesive primer. Adhesive products are a type of coating.

“Adhesive Solid” means the nonvolatile portion of an adhesive that remains after heating a sample of the

material at 110 o degrees C Celsius for one hour.

“Aerosol Adhesive” means an adhesive packaged as an aerosol product in which the spray mechanism is permanently housed in a nonrefillable can designed fo r hand-held application without the need for ancillary hoses or spray equipment. “Aerosol a dhesives ” include “special pur pose spray adhesives, ” “ mist spray adhesives,” and “web spray adhesives” as de fined in the Air Resources Board consumer products regulation found in Title 17 of the California Code of Regulations, section 94507 et seq.

“Airless Spray” means a spray method in which a pump forces the adhesive through an atomizing nozzle at high pressure (1,000 to 6,000 pounds per square inch).

“Any Other Primer” means a coating or adhesive applied to a substrate to improve adhesion of subsequently applied adhesive, except adhesive primer and adhesive bonding primer.

“Architectural Sealant/Primer” means any sealant or sealant primer intended by the manufacturer to be applied to stationary structures, including mobile home s, and their appurtenances. Appurtenances to an architectural structure include, but are not limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters and downspouts, and windows.

“Associated Solvent” means any solvent used in a solvent cleaning machine or for solvent cleaning performed in association with the application of any adhesive product or sealant product.

“Automotive Glass Adhesive Primer” means any adhesive primer intended by the manufacturer to be applied to automotive glass prior to installation with an adhesive/sealant. This primer improves adhesion to the pinch weld and blocks ultraviolet light. Comment [A178]: Our protocol is to add this

lead-in sentence.

Comment [A179]: Modeled on the SJV Rule

4653 defin ition. Existing text in the rule is simplified by using the adhesive product and sealant product terms.

Comment [A180]: The District protocol is to remove degree symbols , abbreviations, and acronyms. Hence, they are spelled out here and

elsewhere.

Comment [A181]: Modeled on the SJV Rule

4653 defin ition; it is used in Section Q.11.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-5 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 5 August 19, 1999[ date of amended rule adoption ] “Bench Scale Project” means a project (other than at a research and development facility) that is operated on a small scale, such as one capable of being located on a laboratory bench top.

“Ceramic Tile Installation Adhesive” means any adhesive intended by the manufacturer for the

installation of ceramic tiles.

“Ceramic Tile ” means a ceramic surfacing unit made from clay or a mixture of clay and other materials.

“Chlorinated Polyvinyl Chloride (CPVC) Welding Adhesive” means any adhesive intended by the manufacturer for the welding of CPVC plastic pipe . CPVC plastic is a polymer of the monomer that contains 67 percent chlorine and is normally identified with a CPVC marking.

“Coating” means a material applied onto or impregnated in to a substrate for protective, decorative, or functional purposes. Such materials include, but are no t limited to, adhesive products, paints, varnishes, sealant products, and stains.

“Compliant Material” means any adhesive product, sealant product, stripper, or solvent that has a reactive organic compound content or composite partial pressure that complies with the applicable limit in Section D, E, F, G, H, or R.

“Computer Diskette Jacket Manufacturing Adhesive” means any adhesive intended by the manufacturer to glue the fold-over flaps to the body of a vinyl computer diskette jacket.

“Contact Bond Adhesive ” or “Contact Adhesive ” means any adhesive intended by the manufacturer to adhere to itself instantaneously upon contact. The ad hesive is applied to both adherends and allowed to become dry, which develops a bond when the adherends are brought together without sustained pressure. for application to both surfaces to be bonded together, which is allowed to dry before the two surfaces are placed in contact with each other, forms an immediate bo nd that is impossible, or difficult, to reposition after both adhesive-coated surfaces are placed in contact with each other, and does not need sustained pressure or clamping of surfaces after the adhesive -coated surfaces have been brought together using sufficient momentary pressure to establish full con tact between both surfaces. Contact adhesive does not include rubber cements that are primarily intended for us e on paper substrates. Contact adhesive also does not include vulcanizing fluids that are desi gned and labeled for tire repair only.

“Contact Bond Adhesive -Special ty Substrates ” or “Specialty Contact Adhesive ” means any contact adhesive that is intended by the manufacturer to be used for the bonding of nonporous substrates to each other, the bonding of decorative laminate in post

- forming application, or for the bonding of decorative laminate to metal, melamine-covered board, or curved surfaces, or when used to bond the bonding of any substrate to metal, rubber, rigid plastic, or wood veneer not exceeding 1/16 inch in thickness.

“Control” means the reduction, by destruction or removal, of the amount of affected pollutants in a gas stream prior to discharge to the atmosphere.

“Control System” means any combination of pollutant captur e system(s) and control device(s) used to reduce discharge to the atmosphere of reactive or ganic compound or toxic air contaminant emissions generated by a regulated operation.

“Cove Base Installation Adhesive” means any adhesive intended by the manufacturer for the installation of cove base (or wall base), which means is generally made of vinyl or rubber, on a wall or vertical surface

at floor level.

“Cyanoacrylate Adhesive” means an adhesive with a cyanoacrylate content of at least 95 percent by weight. Comment [A182]: Some of the new terms stem

from additions to Rule 337.

Comment [A183]: Added for ease of understanding that these materials are coatings

.

Comment [A184]: Modeled on the SJV Rule

4653 defin ition. The term contact adhesive appears several places (e.g., Rule 353 Q.10).

Comment [A185]: Similar to the SJV Rule 4653 definition. Rule 353.Q.10 uses specialty contact

adhesive

.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-6 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 6 August 19, 1999[ date of amended rule adoption ] “Dip Coat Application” means any process in which a substrate is immersed in a solution (or dispersion) containing the coating material, and then withdrawn.

“Drywall Installation” means the installation of gypsum drywall to studs or solid surfaces using an adhesive formulated for that purpose.

“Electrodeposition” means the application of a coating using a water-based electrochemical bath process. The component being coated is immersed in a bath of the coating. An electric potential is applied between the component and an oppositely charged electrode hanging in the bath. The electric potential causes the ionized coating to be electrically attracted, migrated , and deposited on the component being coated.

“Exempt Compound” means any compound identified as an exception to the definition of “reactive organic compound” in Rule 102.

“Fiberglass” means a fiber made fine filaments of from glass and similar in appearance to wool or cotton

fiber

.

“Flexible Vinyl” means nonrigid polyvinyl chloride plastic with at least five percent, by weight, of plasticizer content. A plasticizer means a material, su ch as a high boiling point organic solvent, that means is incorporated into an adhesive to increase its flex ibility, workability, or distensibility, and may be determined using ASTM Method E260- 91 96(2006), “Standard Practice for Packed Column Gas Chromatography,” ASTM International, or from product formulation data.

“Flow Coat Application” means any coating application system, with no air supplied to the nozzle, where paint flows over the part and the excess coating drains back into the collection system.

“Foam ” means a rigid or spongy cellular mass with gas bubbles dispersed throughout.

“Glue” means a hard gelatin obtained from hides, tendons, cartilage, bones, etc. , of animals. Through general use, the term “ glue ” is synonymous with the term “ adhesive. ”

“Grams of Reactive Organic Compound (ROC) per Liter of Adhesive or Sealant, Less Water and Less Exempt Compounds” means the weight of reactive organic compound per combined volume of reactive organic compound and adhesive or sealant soli ds, and can be calculated by the following equation:

Grams of ROCreactive organic compounds W

s ̶ W

w ̶ W

e per liter of adhesi ve or sealant, less = water and less exempt compounds V

m ̶ V

w ̶ V

e

Where: W

s = Weight of volatile compounds in grams

W

w = Weight of water in grams

W

e = Weight of exempt compounds in grams

V

m = Volume of material in liters

V

w = Volume of water in liters

V

e = Volume of exempt compounds in liters

For adhesives or sealants that contain reactive dilu ents, the reactive organic compound content of the adhesive or sealant is determined after curing. Th e grams of reactive organic compound per liter of

adhesive or sealant shall be calculated by the following equation:

Grams of ROCreactive organic compounds W

rs ̶ W

rw ̶ W

re per liter of adhesive or sealant, less = water and less exempt compounds V

rm ̶ V

rw ̶ V

re Comment [A186]: Deleted because the definition is being added to Rule 102.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-7 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 7 August 19, 1999[ date of amended rule adoption ] Where: W

rs = Weight of volatile compounds not consumed during curing in grams

W

rw = Weight of water not consumed during curing in grams

W

re = Weight of exempt compounds not consumed during curing in grams

V

rm = Volume of material not consumed during curing in liters

V

rw = Volume of water not consumed during curing in liters

V

re = Volume of exempt compounds not consumed during curing in liters

“Grams of Reactive Organic Compound Per Liter of Material” means the weight of reactive organic compound per volume of material and can be calculated by the following equation:

W

s - W

w - W

e Grams of ROC per liter of Material =

V

m

Where: W

s = weight of volatile compounds in grams

W

w = weight of water in grams

W

e = weight of exempt compounds in grams

V

m = volume of material in liters

“Hand Application Method” means the application of a surface coating by manually held nonmechanically operated equipment. Such equipment incl udes paint brush, hand-roller, trowel, spatula, dauber, rag or sponge.

“Indoor Floor Covering Installation Adhesive” means any adhesive intended by the manufacturer for the installation of wood flooring, carpet, resilient tile, viny l tile, vinyl backed carpet, resilient sheet and roll, or artificial grass. Ceramic tile ins tallation and the installation of peri meter bonded sheet flooring with vinyl backing onto a non-porous substrate, such as flexible vinyl are excluded from this category.

“Laminate” means a product made by bonding together two or more layers of material.

“Low

- Solids Adhesive, Sealant, or Primer” means any product that contains 120 grams or less of solids per liter of material.

“Marine Deck Sealant/Sealant Primer” means any sealant or sealant primer intended by the manufacturer to be applied to wooden marine decks.

“Metal to Urethane/Rubber Molding or Casting Adhesive” means any adhesive intended by the manufacturer to bond metal to high density or elastome ric urethane or molded rubber materials, in heater molding or casting processes, to fabricate products su ch as rollers for computer printers or other paper handling equipment.

“Multipurpose Construction Adhesive” means any adhesive intended by the manufacturer for the installation or repair of various construction materials, including but not limited to drywall, subfloor, panel, fiberglass reinforced plastic (FRP), ceiling tile, and acoustical tile.

“Noncompliant Material” means any adhesive product, sealant product, stripper, or solvent that has a reactive organic compound content or composite partial pressure that does not comply with the applicable limit in Section D, E, F, G, H, or R.

“Nonmembrane Roof Installation/Repair Adhesive” means any adhesive intended by the manufacturer for the installation or repair of nonmembrane roofs and that means is not intended for the installation of prefabricated single-ply flexible roofing membrane. This category includes plastic or asphalt roof cement, asphalt roof coatings, and cold application cement. Comment [A187]: This term has been moved

into Rule 102.

Comment [A188]: The term appears in the amended Rule 353.B.9 and O.4 provision.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-8 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 8 August 19, 1999[ date of amended rule adoption ] “Outdoor Floor Covering Installation Adhesive” means any adhesive intended by the manufacturer for the installation of floor covering that means is not in an enclosure and means exposed to ambient weather conditions during normal use.

“Panel Installation” means the installation of plywood, pre-deco rated hardboard (or tileboard), fiberglass reinforced plastic, and similar pre-decorated or non-de corated panels to studs or solid surfaces using an adhesive formulated for that purpose.

“Percent Reactive Organic Compound By Weight” means the ratio of the weight of the reactive organic compound to the weight of the material, expressed as a percentage of reactive organic compound by weight. The percent reactive organic compound by weight can be calculated as follows:

W

v %ROCweightPercent reactive organic compound by weight = x100

W

Where: W

v = weight of ROCs reactive organic compounds in grams

W

= weight of material in grams

“Perimeter Bonded Sheet Flooring Installation” means the installation of sheet flooring with vinyl backing onto a nonporous substrate using an adhesive desi gn to be applied only to a strip of up to four inches wide around the perimeter of the sheet flooring.

“Plastic Cement Welding Adhesive Primer” means any primer intended by the manufacturer to prepare plastic substrates prior to bonding or welding.

“Plastic Foam” means a ny foam constructed of plastics.

“Plastics” mean s various synthetic materials chemically formed by the polymerization of organic (carbonbased) substances. Plastics are usually compounded with modifiers, extenders, and/or reinforcers. They are used to produce pipe, solid sheet, film, or bulk products.

“Polyurethane Foams” mean s plastic foams, as defined in “ Whittington ’ s Dictionary of Plastics, ” page 329, and may be either rigid or flexible.

“Polyvinyl Chloride (PVC) Plastic” means a polymer of the chlorinated vinyl monomer that contains 57 percent chlorine and is normally identified with a PVC marking.

“Polyvinyl Chloride (PVC) Welding Adhesive” means any adhesive intended by the manufacturer for the welding of PVC plastic pipe.

“Porous Material” means a substance that has tiny openings, often microscopic, in which fluids may be absorbed or discharged. Such mater ials include but are not limited to wood, paper, corrugated paperboard, and plastic foam.

“Propellant” means a fluid under pressure that expels the contents of a container when a valve means opened.

“Reactive Diluent” means a liquid which is a reactive organic compound during application and one in which, through chemical and/or physical reactions, such as polymerization, 20 percent or more of the reactive organic compound becomes an integral part of a finished material.

“Roadway Sealant” means any sealant intended by the manufact urer to be applied to public streets, highways, and other surfaces, including but not limited to curbs, berms, driveways, and parking lots.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-9 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 9 August 19, 1999[ date of amended rule adoption ] “Rubber” includes any natural or manmade rubber substrate, including but not limited to, styrenebutadiene rubber (SBR), polychloroprene (neoprene) , butyl rubber, nitrile rubber, chlorosulfonated polyethylene (CSM), and ethylene propylene diene terpolymer (EPDM).

“Sealant” means any material with adhesive properties that is formulated primarily to fill, seal, waterproof, or weatherproof gaps or joints between two surfaces. Sealants include caulks.

“Sealant Primer” means any product intended by the manufacturer to be applied to a substrate, prior to the application of a sealant, to enhance the bonding surface.

“Sealant Product” means any sealant and sealant primer. Sealant products are a type of coating.

“Sealant Solid” means the nonvolatile portion of a sealant that remains after heating a sample of the

material at 110 o degrees CCelsius for one hour.

“Sheet

- Applied Rubber Installation” means sheet rubber lining applied to the interior walls of stationary

tanks and rail cars.

“Single

- Ply Roof Membrane” means single sheets of rubber, normally EPDM (ethylene-propylene diene terpolymer), that are applied in a single layer to a building roof (normally a flat roof).

“Single

- Ply Roof Membrane Adhesive” means any adhesive intended by the manufacturer for the installation or repair of single-ply roof membrane. Installation includes, as a minimum, attaching the edge of the membrane to the edge of the roof and applying flashings to vents, pipes, and ducts that protrude through the membrane. Repair includes gluing the ed ges of tears together, attaching a patch over a hole, and reapplying flashings to vents, pipes, or ducts installed through the membrane.

“Single

- Ply Roof Membrane Adhesive Primer” means any primer intended by the manufacturer to clean and promote adhesion of the single-ply roof membrane seams or splices prior to bonding.

“Single

- Ply Roof Membrane Sealant” means any sealant to be used for th e installation or repair of singleply roof membrane to the edge of the roof and applyi ng flashings to vents, pipes, or ducts that protrude through the membrane. Repair includes, but is not li mited to gluing the edges of tears together, attaching a patch to a hole, and reapplying flashings to vents, pipes, or ducts installed through the membrane.

“Solvent” means any liquid containing any reactive organi c compound or any toxic air contaminant, which is used as a diluent, thinner, dissolver, viscosity redu cer, cleaning agent, drying agent, preservative, or other

similar uses.

“Solvent Bonding” has the same meaning as “solvent welding.”

“Solvent Cleaning” means any activity, operation, or process (including, but not limited to, surface preparation, cleanup, or wipe cleaning) performed outs ide of a solvent cleaning machine, that uses solvent to remove uncured adhesives, uncured coatings, uncu red inks, uncured polyester resin material, uncured sealant, or other contaminants, including, but not limi ted to, dirt, soil, oil, lubricants, coolants, moisture, fingerprints, and grease, from parts, products, tools, machinery, application equipment, and general work areas. Cleaning spray equipment used for the application of coating, adhesive, ink, polyester resin material,

or sealant is also considered to be solvent clea ning irrespective of the spray material being cured.

“Solvent Cleaning Machine” means any device or piece of equipment that uses solvent liquid or vapor to remove soils, moisture, or other contaminants from the surfaces of materials. Types of solvent cleaning machines include, but are not limit ed to, batch cold, batch vapor, in-l ine cold, in-line vapor, remote reservoir, and gas-path solvent cleaners. Buckets, p ails, and beakers with capacities of 3.785 liters (1.00 gallon) or less are not considered solvent cleaning ma chines. However, the use of such a container or similar containers (e.g., hand-held spray bottles) wi th a liquid solvent for cleaning is considered to beSTAFF REPORT

– PARs 330, 337, 349, & 353 Page G-10 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 10 August 19, 1999[ date of amended rule adoption ] solvent cleaning. Any device or piece of equipment used exclusively for stripping shall not be considered to be a solvent cleaning machine.

“Solvent Welding” means the softening of the surfaces of two substrates by wetting them with solvents and/or adhesives, and joining them together with a chemical and/or physical reaction(s) to form a fused

union.

“Stripper” means any liquid that is applied to a surface to re move cured or dried coatings such as primers, adhesives (e.g., debonding or unglueing), to pcoats, and temporary protective coatings.

“Structural Glazing Adhesive” means any adhesive intended by the manufacturer to adhere glass, ceramic, metal, stone, or composite pa nels to exterior building frames.

“Subfloor Installation” means the installation of subflooring material over floor joists, including the construction of any load bearing joists. Subflo oring means covered by a finish surface material.

“Surface Preparation Solvent” means a solvent used in the cleaning of a substrate to remove dirt, oil, and

other contaminants (e.g., uncured coatings) . This surface cleaning means is typically done prior to the application of primers, adhesives, or sealants.

“Thin Metal Laminating Adhesive” means any adhesive intended by the manufacturer to bond multiple layers of metal to metal or metal to plastic in the pr oduction of electronic or magnetic components in which the thickness of the bond line(s) means is less than 0.25 mil (0.00025 inch, 0.00635 millimeter)

.

“Tire Repair” means the expanding of a hole, tear, fissure, or blemish in a tire casing by grinding or gouging, applying adhesive, and filling the hole or crevice with rubber.

“Tire Retread Adhesive” means any adhesive intended by the manu facturer to be applied to the back of precure tread rubber and to the casing and cushion rubber. It may also be used to se al buffed tire casings to prevent oxidation while the tire means is being prepared for a new tread.

“Traffic Marking Tape” means preformed reflective film intended by the manufacturer to be applied to public streets, highways, and other surfaces, including but not limited to curbs, berms, driveways, and parking lots.

“Traffic Marking Tape Adhesive Primer” means any primer intended by the manufacturer to be applied to surfaces prior to installation of traffic marking tape.

“Viscosity” means the internal friction of a liquid that makes it resistant to flow.

“Volatile Organic Compound (VOC)” has the same meaning as “reactive organic compound” as defined

in Rule 102 , Definitions

. Tertiary-butyl acetate (also known as t-bu tyl acetate or tBAc) shall be considered exempt as a reactive organic compound only for purposes of reactive organic compound emissions limitations or reactive organic compound content requirem ents and will continue to be a reactive organic compound for purposes of all record keeping, emissions reporting, photochemical dispersion modeling, and inventory requirements which apply to reactive organic compounds.

“Waterproof Resorcinol Glue” means a two-part resorcinol-resin-based adhesive designed for applications where the bond line must be resistant to conditions of continuous immersion in fresh or salt

water.

“Wood Flooring Installation” means the installation of a wood floor surface, which may be in the form of parquet tiles, planks, or strip-wood.

“Wood Parquet Flooring” means wood flooring in tile form constructed of smaller pieces of wood which are joined together in a pattern by the maker to form the tile. Comment [A189]: Solvent, solvent cleaning

, and solvent cleaning machine are the same

definitions found in Rule 321. Solvent includes any liquid containing any toxic air contaminant.

Comment [A190]: Including rule titles for

referenced rules follows an EPA recommendation.

Comment [A191]: The tBAc qualifier addresses

EPA concerns.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-11 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 11 August 19, 1999[ date of amended rule adoption ] “Wood Plank Flooring” means solid or laminated wood in plank form.

D. Requirements

– Reactive Organic Compound Limits for Specific Applications of Adhesive Product s , or Adhesive Bonding Primers, Adhesive Primers, Sealant Product s , Sealant Primers, or Any Other

Primer

Except as provided in Sections E and I of this rule

, ano person shall not apply nonaerosol adhesive product s , adhesive bonding primers, adhesive primers, or sealant product s , sealant primers, or any other primer that are defined listed under the Table 353-1 product categories and that have a reactive organic compound content (grams per liter [g/l], less water and less exempt compounds) in excess of the Table 353- 1 limits. For low-solids adhesives, sealants, or pr imers, the reactive organic compound content is based on

a g/l grams of reactive organic compound per liter of material basis.

TABLE 353-1. REACTIVE ORGANIC COMPOUND LIMITS FOR SPECIFIC APPLICATIONS

TYPE PRODUCT CATEGORY ROC LIMITS (less water and exempt compounds)

On and After

0 1/01/2000 08/19/1

999 On and After 01/01/2000[ 12 months after the date of amended rule adoption ] (g/l) (lb/gal) (g/l) (lb/gal)

1. Adhesives ABS welding 400 3.3 400 3.3

Ceramic tile installation 130 1.1 130 1.1 Computer diskette jacket manufacturing 850 7.1 850 7.1

Contact bond 540 4.5 250 2.1 Contact bond-specialty substrates 540 4.5 400 3.3

Cove base installation 150 1.3 150 1.3 CPVC welding 490 4.1 490 4.1 Indoor floor covering installation (except ceramic tile installation) 150 1.3 150 1.3

Metal to urethane/rubber molding or casting 850 7.1 850250 7.12.1 Multipurpose construction (except cove base installation) 200 1.7 20070 1.70.6

Nonmembrane roof installation/repair 300 2.5 300 2.5 Other plastic cement welding 510 4.3 510250 4.32.1 Outdoor floor covering installation 250 2.1 250 2.1 Perimeter bonded sheet vinyl flooring

installation 660 5.5 660 5.5

PVC welding 510 4.3 510500 4.34.2 Sheet-applied rubber installation 850 7.1 850 7.1 Single-ply roof membrane installation/repair 250 2.1 250 2.1 Structural glazing 100 0.8 100 0.8 Thin metal laminating 780 6.5 780 6.5

Tire retread 100 0.8 100 0.8 Traffic marking tape 150 1.3 150 1.3 Waterproof resorcinol glue 170 1.4 170 1.4 Comment [A192]: Our practice is to improve text flow by changing the sentence structure in this

manner.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-12 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 12 August 19, 1999[ date of amended rule adoption ] TABLE 353-1. REACTIVE ORGANIC COMPOUND LIMITS FOR SPECIFIC APPLICATIONS

TYPE PRODUCT CATEGORY ROC LIMITS (less water and exempt compounds)

On and After

0 1/01/2000 08/19/1

999 On and After 01/01/2000[ 12 months after the date of amended rule adoption ] (g/l) (lb/gal) (g/l) (lb/gal)

2. Sealants

Architectural 250 2.1 250 2.1

Marine deck 760 6.3 760 6.3 Nonmembrane roof installation/repair 300 2.5 300 2.5 Roadway 250 2.1 250 2.1 Single-ply roof membrane 450 3.8 450 3.8

Other 420 3.5 420 3.5

3. Adhesive Primers Automotive glass 700 5.8 700 5.8 Plastic cement welding 650 5.4 650 5.4 Single-ply roof membrane 250 2.1 250 2.1 Traffic marking tape 150 1.3 150 1.3

Other 250 2.1 250 2.1

4. Sealant Primers

Architectural

– non porous 250 2.1 250 2.1

Architectural

– porous 775 6.5 775 6.5

Marine deck 760 6.3 760 6.3

Other 750 6.3 750 6.3

E. Requirements

– Reactive Organic Compound Limits for Nonspecific Applications of Adhesive

Product s , Adhesive Bonding Primers, Adhesive Primers, or Sealant Product s , Sealant Primers, or Any Other Primer onto Substrates

Except as provided below and in Section I of this rule

, a no person shall not apply nonaerosol adhesive product s , adhesive bonding primers, adhesive primers, or sealant product s , sealant primers, or any other primer to a substrate that have a reactive organic compound content ( g/lgrams per liter , less water and less exempt compounds) in excess of the Table 353-2 limits. For low-solids adhesives, sealants, or primers, the reactive organic compound content is based on a g/l grams of reactive organic compound per liter of

material basis.

The limit for a nonspecific application onto a substrate where an operator:

1. Bonds dissimilar substrates together, is the applicable substrate category with the highest reactive organic compound content.

2. Uses an adhesive or sealant listed in Table 35 3-1, is the limit specified in Table 353-1 for that particular product category. Comment [A193]: Deleting outdated limits simplifies the table.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-13 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 13 August 19, 1999[ date of amended rule adoption ] TABLE 353-2. REACTIVE ORGANIC COMPOUND LIMITS FOR NONSPECIFIC APPLICATIONS

OF ADHESIVE PRODUCT S , ADHESIVE BONDING PRIMERS, ADHESIVE PRIMERS, AND

SEALANT PRODUCT S , SEALANT PRIMERS, OR ANY OTHER PRIMER ONTO SUBSTRATES

SUBSTRATE/APPLICATION ROC LIMITS (less water and exempt compounds)

On and After

08/19/1999 On and After [ 12 months after the date of amended rule adoption ]
(g/l) (lb/gal) (g/l) (lb/gal)
Flexible vinyl 250 2.1 250 2.1 Fiberglass 200 1.7 80 0.7

Metal 30 0.3 30 0.3

Porous material 120 1.0 50 0.4

Rubber 250 2.1 250 2.1

Other substrates 250 2.1 250 2.1

F. Requirements

– Aerosol Adhesives Reactive Organic Compound Limit

Except as provided in Section I of this rule

, a no person shall not use any aerosol adhesive unless the reactive organic compound content , including the propellant, does not exceed 75 percent by weight complies with the Air Resources Board consumer produ cts regulation found in Title 17 of the California Code of Regulations, section 94507 et seq

.

G. Requirement

– Cleanup Solvent and/or Cleanup Method

1. Before [ one year from the date of amended rule adoption ], Except except as provided in Section I

of this rule , no person shall use materials containing reactive organic compound for the removal of

uncured adhesive product s , adhesive bonding primers, adhesive primers, or uncured sealant product s , sealant primers, or any other primer from surfaces, other than spray application equipment, unless the reactive organic compound composite vapor partial pressure of the solvent

used is less than 45 millimeters (mm) of mercury (Hg) at 20 degree s (°) Celsius (C)

.

Effective [ one year from the date of amended rule adoption ], except as provided in Sections G.2 and I, no person shall use any solvent containing more than 25 grams of reactive organic compound (0.21 pound of reactive organic compound per gallon) per liter of material for the removal of uncured adhesive products or uncured sealant products from surfaces.

2. Spray application equipment: Before [ one year from the date of amended rule adoption ], Except
except as provided in Section I of this rule , either one of the following shall be used for cleaning, flushing or soaking of filters, flushing lines, pipes, pumps, and other parts of the application equipment:

a. An enclosed cleaning system, or an equivalent cleaning system as determined by the test

method referenced in Section N. 89 of this rule , or

b. A solvent with a reactive organic compound content of 70 grams of reactive organic compound per liter (0.6 lb/galpound per gallon ) of material or less. Parts containing dried adhesive may be soaked in an organic solvent as long as the reactive organic compound composite vapor partial pressure , excluding water and exempt compounds, of

the solvent is 9.5 mm of Hgmillimeters of mercury at 20 °C degrees Celsius or less and is kept in a closed container, which shall be closed except when depositing or removing parts or materials from the container. Comment [A194]: Both ARB and EPA recommend a 25 g/l limit on the solvent's ROC

content.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-14 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 14 August 19, 1999[ date of amended rule adoption ] Effective [ one year from the date of amended rule adoption ], except as provided in Section I, any person cleaning spray application equipment with a solvent containing more than 25 grams of reactive organic compound per liter (0.21 pound of reactive organic compound per gallon) of material shall use an enclosed cleaning system, or equipment that is proven to the satisfaction of the Control Officer to be equally effective as an en closed cleaning system at controlling emissions. “Equal effectiveness” of an alternative cleaning system shall be determined by the test method

referenced in Section N.8. If an enclosed clea ning system is used, it shall totally enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing, and draining procedures, and it shall be used according to the manufacturer’s recommendations and be closed when not in use.

H. Requirements

– Surface Preparation Solvent

Before [ one year from the date of amended rule adoption ], Except except as provided in Section I of this

rule and for single-ply roofing, no person shall use materials containing reactive organic compounds for surface preparation unless the reactive organic compound content of the solvent is 70 grams of reactive organic compound per liter (0.6 lb/galpound per gallon ) of material or less. For single-ply roofing surface preparation solvent, the reactive organic compound composite vapor partial pressure , excluding water and exempt compounds, shall not exceed 45 mm of Hg at 20°Cmillimeters of mercury at 20 degrees Celsius

.

Effective [ one year from the date of amended rule adoption ], except as provided in Section I and for singleply roofing, no person shall use any solvent containing more than 25 grams of reactive organic compound per liter (0.21 pound of reactive organic compound per gallon) of material for surface preparation.

I. Requirements

– Alternative Compliance Provision

A person may comply elect to use an add-on control system as an alternative to meeting the requirements with the provisions of Sections D, E, F, G, and H , Q, and R of this rule by using approved add-on air pollution control equipment , provided thatall of the applicable requirements below are met:. Any person choosing to install such control system shall obtain an Authority to Construct from the District prior to

installation.

1. The reactive organic compound emissions from such operations and/or materials are reduced by at least 85 percent overall capture and destruction efficiency (the capture efficiency multiplied by the control device efficiency) of the total system shall be at least 85.0 percent , by weight

,. Alternatively, the control device reactive organic compound exhaust concentration shall not exceed 10 parts per million by volume as propan e or other limit approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officer.

2. Combustion temperature is shall be continuously monitored when operating a thermal incinerator

,.

3. Inlet and exhaust gas temperatures are shall be continuously monitored when operating a catalytic

incinerator

,.

4. Control device efficiency is shall be continuously monitored when operating a carbon adsorber or control device other than a thermal or catalytic incinerator ., and

5. Written approval for such equipment, in the form of an Authority to Construct and a Permit to Operate, is received from the Control Officer.Co mpliance through the use of an emission control system shall not result in affected pollutant emissions in excess of the affected pollutant emissions that would result from compliance with Sections D, E, F, G, H, Q, and R. Comment [A195]: Modeled on the Rule 321.M.3 provisions.

Comment [A196]: Revising the limit from 70 to 25 g/l follows ARB and EPA suggestions. The single -ply roofing surface preparation solvent provision is being deleted. The removal of the special category and the solvent’s ROC composite partial pressure limit is consistent with the current requirements in SJV 4653 and SC 1171 rules.

Comment [A197]: The addition of and toxic air

contaminant stems from similar text in Rule

321.N.1.

Comment [A198]: Similar to provision in Rule

321.N.6. ( Reactive organic compound changed to affected pollutant to include TACs.)STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-15 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 15 August 19, 1999[ date of amended rule adoption ] J. Requirements

– Storage of Reactive Organic Compound Containing Materials General Operating

Any person who owns, operates, or uses any application equipment to apply any adhesive products or sealant products shall ensure the coating operation and any solvent cleaning associated with such operation meets the following requirements:

1. All reactive organic compound

- containing materials, used or unused, including , but not limited to, adhesive products, sealant products, and reactive organic compound-laden cloth or paper used in in solvent cleaning and stripping of cured adhesives, shall be stored or and disposed of in non

absorbent and nonleaking containers equipped with tight-fitting covers, which shall be closed except when depositing or removing materials from the container

. All covers shall be in place unless adding material to or removing material from the containers, the containers are empty, or doing maintenance/inspection of the containers.

2. All application equipment, ventilation system, an d emission control equipment shall be installed, operated, a nd maintained consistent with the manufacturer’s specifications.

3. Waste solvent, waste solvent residues, and any other waste material that contains reactive organic compounds shall be disposed of by one of the following methods:

a. A commercial waste solvent reclamation service licensed by the State of California.

b. At a facility that is federally or state license d to treat, store or dispose of such waste.

c. Recycling in conformance with Section 25143.2 of the California Health and Safety

Code.

4. All covers, valves, drain plugs, and other cl osure devices designed to reduce evaporation of reactive organic compound-containing materials shall not be removed or opened except to process work or to perform monitoring, inspections, maintenance, or repairs that require the removal of the

covers or other closure devices.

5. Any reactive organic compound-containing mate rial spills shall be wiped up immediately and the used absorbent material (e.g., cloth, paper, sand, sa wdust, etc.) shall be stored in closed containers

that are handled in accordance with Section J.1.

6. The handling and transfer of coatings, stripper s, and cleaning solvents to or from enclosed systems, vats, waste containers, and other cleanin g operation equipment that hold or store fresh or spent coatings, strippers, and cleaning solvents shall be conducted in such a manner that minimizes spills.

7. Containers used to store adhesive products, an d sealant products, solvent, or any waste material that contains reactive organic compounds subject to this rule shall be marked or clearly labeled indicating the name of the material they contain.

K. Requirements

– Prohibition of Sales

1. Except as provided in Section B. 310 of this rule

, after the specified effective dates, no person shall supply, sell, or offer for sale any nonaerosol adhesive s product, adhesive bonding primers, adhesive primers, sealants or sealant product, sealant primers, or any other primer that, at the time of sale, is listed in Section D Table 353-1 and exceeds the corresponding reactive organic compound limit s therein. listed in Table 353-1 and is defined under a product category in Table

353-1.

2. Except as provided in Section B. 310 of this rule, no person shall su pply, sell, or offer for sale, any aerosol adhesive unless, at the time of sale, the reactive organic compound content, including the Comment [A199]: The housekeeping provisions are similar to requirements found in Rule 321.D.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-16 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 16 August 19, 1999[ date of amended rule adoption ] propellant, does not exceed 75 percent by weightprovisions of the Air Resources Board consumer product regulation, found in Title 17 of the California Code of Regulations, section 94507 et seq.,

are met

.

L. Requirements

– Manufacturer Compliance Statement and Labeling

The manufacturer of any adhesive product s , adhesive bonding primers, adhesive primers, or sealant product s , sealant primers, or any other primer subject to this rule shall display the include a designation of

the maximum reactive organic compound or volatile organic compound content as supplied, expressed in grams per liter or pounds per gallon excluding w ater and exempt compounds determined by from the appropriate test method, on labels or containersand data sheets . This designation shall display include recommendations regarding thinning, reducing, or mixing with any other reactive organic compound- or volatile organic compound

- containing material. This information shall include the maximum reactive organic compound or volatile organic compound content on an as-a pplied basis when used in accordance

with the manufacturer's recommendations.

M. Requirements

– Prohibition of Specification

No person shall solicit, require for use, or specify the application of any adhesive product s, adhesive bonding primers, adhesive primers, sealant product s, or associated solvent sealant primers, or any other primer, if such use or application results in a violation of th e provisions of this rule. This prohibition shall apply to all written or oral contracts.

N. MonitoringRequirements

– Compliance Provisions and Test Methods

1. The volatile organic compound and solids content of all nExcept as specified in Section N.4,

n onaerosol adhesive product s, adhesive primerssealant products , and cleaning associated solvents reactive organic compound content, except as specified in Section N.4 of this rule, shall be determined using Environmental Protection Agency Reference Method 24 (40 CFR Part 60, Appendix A), its constituent methods, or an eq uivalent method approved by the Environmental Protection Agency, the Air Resources Board, and the Control Officeror South Coast Air Quality Management District Method 304

. The reactive organic compound content of materials containing 50 grams of reactive organic compound per liter or less shall be determined by the South Coast Air Quality Management District Method 313-91, “ Determination of Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, ” June 1993, or any other test methods approved by the Environmental Protection Agency, the Air Resources Board, and the

Control Officer.

2. Exempt organic compounds shall be determined using ASTM D4457- 19 91

, “ Standard Test Method for Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings by Direct Injection into a Gas Chromatograph, ” ASTM International

. Alternatively, determination of exempt compounds may be performed in accordance with the South Coast Air Quality Management District Method 303- 91, “Determination of Exempt Compounds,” August

1996. For exempt compounds where no reference test method is available, a facility requesting the exemption shall provide appropriate test methods approved by the Control Officer and approvable by the Air Resources Board and the Environmental Protection Agency.

3. The volatile reactive organic compound content of aerosol adhesives and aerosol adhesive primers shall be determined using South Coast Air Quality Management District Test Method 305 -91, “Determination of Volatile Organic Compounds in Aerosol Applications,” June 1993, or Air

Resources Board Method 310 , “Determination of Volatile Organic Compounds in Consumer Products and Reactive Organic Compounds in Aerosol Coating P roducts,” June 22, 2000, upon the Environmental Protection Agency approval of Method 310.

4. The volatile reactive organic compound content of any plastic welding cement adhesive or primer shall be determined using South Coast Air Quality Management District Method 316A -92, Comment [A200]: Modeled on the VC Rule 74.20.B.12 provisions.

Comment [A201]: EPA recommended referring

to SC Method 313 for d etermining ROC content of materials containing < 50 g/l.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-17 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 17 August 19, 1999[ date of amended rule adoption ] “Determination of Volatile Organic Compound (VOC) in Materials Used for Pipes and Fittings,”

October 1996

.

5. The composite vapor pressure of organic compounds in cleaning materials shall be determined by quantifying the amount of each compound in the blend using gas chromatographic analysis (ASTM E260-96) for organics and ASTM D3792-91 for water content, as applicable, and the following equation:



# ¦ ¦ ¦

  n

i n

1 i i i e e w w i n

i i i

c

Mw W Mw W Mw W Mw VP W

Pp

1 1

/ / / /

Where :
Pp

c = VOC composite partial pr essure at 20°C, in mm Hg.

W

i = Weight of the “i”th VOC compound, in grams, as determined by ASTM E260 -96.

Ww = Weight of water, in grams as determined by ASTM D3792-91

W

e = Weight of the “i”th exempt compound, in grams, as determined by ASTM E260 -96.

Mw i = Molecular w eight of the “i”th VOC compound, in grams per grams -mole, as given in

chemical reference literature.

Mw

w = Molecular weight of water, 18 grams per g - mole.

MW

e = Molecular weight of the “i”th exempt compound, in grams per g - mole, as given in

chemical reference literature.

VP i = Vapor pressure of the “i”th VOC compound at 20°C, in mm Hg, as determined by

Section N.6 of this Rule.

5. Reactive organic compound composite partial pressures shall be measured using ASTM D 2879- 1997, “ Standard Test Method for Vapor Pressu re-Temperature Relationship and Initial Decomposition Temperature of Liquids by Isoten iscope,” ASTM International, in combination

with the formula in the Rule 102 definition of “ reactive organic compound composite partial pressure,” manufactur er's specified reactive organic compound composite partial pressure, or an accepted scientific reference approved the Envi ronmental Protection Agency, the Air Resources Board, and the Control Officer.

6. The vapor pressure of each single component compound may be determined from ASTM D2879- 96 or may be obtained from a published source approved by the Control Officer, such as the sources referenced in 40 CFR 52.741, or the most current edition of a published source, including, but not limited to: a). The Vapor Pressure of Pure Substances, Boublik, Fried, and Hala; ElsevierScientific Publishing Company, New York; b). Perry's Chemical Engineer's Handbook, McGrawHill Book Company; c). CRC Handbook of Chemistry and Physics, Chemical Rubber Publishing Company; and d) Lange's Handbook of Chemistry, John Dean, editor, McGraw-Hill Book Company.

76 . The measurement of capture efficiency for reactive organic compound emissions of an emission control system shall be conducted and reported in accordance with the recently approved Environmental Protection Agency Technical Document "Guidelines for Determining Capture Efficiency," issued January 9, 1995, or a District capture efficiency determination method approved by the Environmental Protection Agency determined by verifying the use of a Permanent Total Enclosure and 100 percent capture efficiency as defined by Environmental Protection Agency Method 204, “ Criteria for and Verification of a Permanent or Temporary Total Comment [A202]: Replaced by reactive organic compound composite partial pressure (Rule 102).STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-18 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 18 August 19, 1999[ date of amended rule adoption ] Enclosure.” Alternatively, if an Environmental Protection Agency Method 204 defined Permanent Total Enclosure is not employed, capture efficiency shall be determined using a minimum of three sampling runs subject to data quality criteria presented in the Environmental Protection Agency technical guidance document “ Guidelines for Determining Capture Efficiency, January 9, 1995.” Individual capture efficiency test runs subject to the Environmental Protection Agency technical guidelines shall be determined by:

a. The Temporary Total Enclosure approach of Environmental Protection Agency Methods

204 thro ugh 204F; or

b. The South Coast Air Quality Management District “ Protocol for Determination of Volatile Organic Compounds (VOC) Capture Efficiency, ” May 1995

87 . The measurement of control device efficiency for reactive organic compound emissions shall be in accordance with determined by Environmental Protection Agency Methods 25, 25A, 25B, or the South Coast Air Quality Management District Method 25.1, “ Determination of Total Gaseous Non-Methane Organic Emissions as Carbo n,” February 1991, or the South Coast Air Quality Management District Method 25.3, “ Determination of Low Concentration Non-Methane NonEthane Org anic Compound Emissions from Clean Fueled Combustion Sources,” March 2000, as applicable. Environmental Protecti on Agency Test Method 18 or Air Resources Board Method 100.422, “Exempt Halogenated VOCs in Gases,” September 12, 1990, shall be used to determine emissions of exempt compounds.

98 . The active and passive solvent losses from spray gun cleaning systems shall be determined using South Coast Air Quality Management District's

, "General Test Method for Determining Solvent Losses from Spray Gun Cleaning Systems," dated October 3, 1989. The test solvent for this determination shall be any lacquer thinner with a minimum vapor reactive organic compound composite partial pressure of 105 mm of Hgmillimeters of mercury at 20 q C degrees Celsius , and the minimum test temperature shall be 15 q C degrees Celsius

.

109 . To determine if a diluent is a reactive diluent, the percent of the reactive organic compound that becomes an integral part of the finished material shall be determined using the South Coast Air Quality Management District Method 316A

- 92, “Determination of Volatile Organic Compound (VOC) in Materials Used for Pipes and Fittings ,” October 1996

.

10. Application equipment coating transfer effic iencies shall be measured using South Coast Air Quality Management District Method “ Spray Equipment Transfer Efficiency Test Procedure for Equipment User, ” May 1989.

11. The capture efficiency requirement for toxic air contaminant emissions that are not reactive organic compounds shall be determined by using the methods described in Section N.6 modified in a manner approved by the District to quantify the mass of liquid or gaseous reactive organic compounds and/or toxic air contaminants.

12. The control device efficiency requirement for to xic air contaminant emissions that are not reactive organic compounds shall be determined using:

a. an Environmental Protection Agency approved test method or methods, or

b. in the case where there is no Environmental Protection Agency approved test method, a District approved detection method applicable for each target toxics specie.

c. the Control Officer may require more than one test method on any emission control device where necessary to demonstrate that the overall efficiency is at least 85 percent by weight in reducing emissions of reactive organic compounds and/or toxic air contaminants. Any technique t o convert “parts per million by volume” test method Comment [A203]: EPA recommended that the

Distri ct model the provisions on SC Rule 1122(h)(7)(A) text.

Comment [A204]: These changes follow EPA’s

recommendation that the District model the provisions on SC Rule 1122(h)(7)(B) text.

Comment [A205]: Similar to the Rule 321.P.3 requirements.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-19 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 19 August 19, 1999[ date of amended rule adoption ] results to either 1) “parts per million by weight,” or 2) “mass emission rates” (e.g., pounds per hour) shall first be approved by th e Control Officer and, if such approval is not provided, then the technique shall not be used to show compliance with this rule.

13. Viscosity will be determined by ASTM D 1084-88 , “Standard Test Methods for Viscosity of Adhesives,” ASTM International.

14. Emissions of reactive organic compounds from the exhaust of an emission control system shall be measured by the Environmental Protection Agency Method 25, in combination with Environmental Protection Agency Method 18 or the California Air Resources Board Method 422, “Exempt Halogenated VOCs in Gases,” September 12, 1990 ( to determine emissions of exempt compounds).

15. When more than one test method or set of test methods are specified for any testing, a test result showing an exceedance of any limit of this rule shall constitute a rule violation.

16. The Environmental Protection Agency test methods in effect on [ date of amended rule adoption ] shall be the test methods used to meet the requirements of this rule.

O. Requirements

– Recordkeeping

Any person subject to this rule that manufactures or applies any adhesive product or , adhesive bonding primer, adhesive primer, sealant product, sealant primer, or any other primer shall comply with the following requirements:. Any owner or operator of a ny stationary source comprised of more than one facility may comply with the following requirements on a facility basis.

1. Maintain a current list file of each all adhesive, adhesive bonding primer, adhesive primer, sealant, sealant primer, any other primer, and solvent reactive organic compound-containing materials in

use at the stationary source subject to this ruleand in storage . The file shall provide all of the data necessary to evaluate compliance and shall include , but not be limited to, the following information, as applicable:

a. A data sheet or material list giving the material name, manufacturer identification , and material application (e.g., brand name, stock identification number).;

b. application method;

c. material type, manufacturer’s specific use instructions (e.g., specific use for which the material is intended), type operation (e.g., coa ting, stripping, or solvent cleaning), and, for coating operations, the product type, type of substrate coated, and type of application (i.e., the adhesive product and sealant product type from Table 353-1 or Table 353-2);

bd

. Any catalysts, reducers, or other components used and the specific mix ing ratio.data (e.g., component volumes or weights) of each component for each batch sufficient to determine the mixture’s reactive organic compound content ;

ce

. Tt he applicable corresponding reactive organic compound content limit (s) or vapor pressure limit from Sections D, E, F, G, and H of this rule from Sections D, E, F, G, H,

and R and the actual as applied reactive organic compound content of the materials used., as applied, or If complying using the “ reactive organic compound vapor composite partial pressure ” method, provide the actual reactive organic compound composite partial

pressure of the adhesive, sealant, primer, or solvent materials used.

f. current adhesive product, sealant product, stripper, and solvent manufacturer specification sheets, Material Safety Data Sheets, product data sheets, or air quality data sheets, which list the reactive organic compound content of each material in use at the Comment [A206]: Essentially the same as Rule 321.P.4 provisions.

Comment [A207]: Added per the EPA recommendation in the Technical Support Document for SJV Rule 4605 (June 2009).STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-20 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 20 August 19, 1999[ date of amended rule adoption ] stationary source subject to this rule. Compliance with this provision may be done by ensuring the manufacturer’s specifications are listed on the product container.

2. Maintain records for each reacti ve organic compound-containing material purchased for use at the stationary source. The records shall includ e, but not be limited to, the following:

a. material name and manufacturer identification (e.g., brand name, stock identification number); and

b. material type (e.g., adhesive product and sealant product type from Tables 353-1 and 353-2, cleanup solvent, stripper, etc.).

3. Maintain records of the disposal method each time waste solvent, or waste solvent residue, or other waste material that contain reactive organic compounds is removed from the stationary source for disposal.

24

. Maintain records of the monthly volume of each adhesive, adhesive bonding primer, adhesive primer, sealant, sealant primer, other primers, or solvent used.For each material maintained in response to Section O.1.a, maintain, at a minimum, on a monthly basis for compliant material and on a daily basis for noncompliant material, a record of the following:

a. volume used (gallons per day, gallons per month);

b. reactive organic compound content (grams per liter or pounds per gallon); and

c. resulting reactive organic compound emissions (pounds per day, pounds per month).

35

. When compliance is achieved through the use of add-on For any stationary source that uses

emission control equipment , as an alternative to meeting the requirements of Sections D, E, F, G, H, Q, or R, maintain daily records on a daily basis of key operating parameter s values and maintenance procedures that demonstrate continuo us operation and compliance of the for the emission control equipment during periods of emission producing activities shall be maintained. These parameters shall, includinginclude , but not be limited to:

a. Hours of operation .;

b. Routine and nonroutine maintenance.All maintenance work that requires the emission control system to be shut down;

c. The applicable information specified in Section I of this rule.All information needed to demonstrate continuous compliance with Secti on I, such as temperatures, pressures,

and/or flow rates.

d. The daily volume of each noncompliant ad hesive, sealant, primer, or solvent used.

46

. All Any records shall be required to be maintained pursuant to this rule shall be kept on site for at

least two ( 2 ) years and shall be available for inspection unless a longer retention period is otherwise required by state or federal regulation(s)

. Such records shall be readily available for Thereafter, the records shall be maintained either on site or readily available for expeditious inspection and review by the Districtfor an additional three (3) years

.

P. Rule Effective DateCompliance Schedule

Any person subject to this rule shall meet the following compliance schedule: Comment [A208]: The daily recordkeeping provision was added for consistency with the EPA “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.”

Comment [A209]: Subsection 5 text mirrors the Rule 321.R.1.c provisions.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-21 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 21 August 19, 1999[ date of amended rule adoption ] 1. By [ 30 days from the date of amended rule adoption ], comply with Section J, Requirements - General Operating.

2. By [ six months from the date of amended rule adoption ], comply with the recordkeeping provisions in the following Sections:

a. O.1.d - mixing data,

b. O.1.e - reactive organic compound content da ta or stripper composite partial pressure data,

c. O.2 - purchase records,

d. O.3 - waste disposal records, and

e. O.4 - daily records for noncompliant materials.

3. By [ one year from the date of amended rule adoption ], comply with the applicable provisions in Sections G and H that have a phased-in effective date.

4. By [ one year from the date of amended rule adoption ], comply with Section Q, R, and T requirements.

5. By [ date of amended rule adoption ], comply with all other provisions of this rule.

Q. Requirement

– Adhesive and Sealant Application Equipment

Effective [ one year from the date of amended rule adoption ], no person shall apply adhesives or sealants unless the application is performed with equipment operating according to the manufacturers operating guidelines. In addition, except as provided in Secti on I, the application method employed shall be one of the following:

1. Electrostatic spray application, or

2. Flow coat application, or

3. Dip coat application, or

4. Roll Coater, or

5. High volume low pressure spraying equipment, or

6. Electrodeposition, or

7. Hand application methods, or

8. Any other application method approved by the Co ntrol Officer, the Air Resources Board, and the Environmental Protection Agency, that has a coating tr ansfer efficiency equivalent to or greater than 65 percent efficiency as measured using the test method specified in Section N.10.

9. Except as otherwise provided in Section Q.10, air-atomized spray may only be used for the application of contact adhesive s or specialty contact adhesives.

10. For adhesive products and sealant products with an as applied viscosity of 200 centipoise or greater, airless spray, air-assisted air less, and air-atomized spray may be used

. Comment [A210]: The compliance schedule provision was expanded in response to a request from Industry.

Comment [A211]: Section Q was modeled on

the SJV Rule 4653 .5.2 and the SC Rule 1168 (c)(5) provisions.

Comment [A212]: Similar to the SJV Rule 4653.5.2.8 provisions.

Comment [A213]: Stems from the SJV Rule 4653.5.2.9 provision.

Comment [A214]: Modeled on the SC Rule 1168(c)(5)(H) provision.STAFF REPORT

– PARs 330, 337, 349, & 353 Page G-22 June 21, 2012

[ Annotated draft of June 21, 2012 ] Santa Barbara County APCD Rule 353 353 - 22 August 19, 1999[ date of amended rule adoption ] R. Requirements

– Coating Stripper Use

Effective [ one year from the date of amended rule adoption ], except as provided in Section I, no person shall apply any stripper or solicit the use of any stripper unless it complies with one or both of the following:

1. The stripper contains less than 300 grams of reactive organic compound per liter (2.5 pounds of reactive organic compound per gallon) of material.

2. The stripper has a reactive organic compound compos ite partial pressure equal to or less than 9.5 millimeters of mercury at 20 degrees Celsius.

S. Reporting Requirements

Submittal of an annual report to the District is required if a person holds a permit for applying adhesive products or sealant products subject to this rule. The annual report shall be due March 1 and it shall contain the following information for the previous calendar year:

1. monthly totals of compliant and noncompliant material used based on the records required by Section O.4,

2. annual totals (gallons) based on each of the coating’s

, solvent’s , and stripper’s monthly data, and

3. name and address of the owner or operator, an d the Permit to Operate number that the adhesive products and/or sealant products ap plication operations are subject to.

T. Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solvent cleaning machine shall comply with the applicable provisions of Rule 321, Solvent Cleaning Machines and Solvent Cleaning.

Click here to return to the list of Appendices in the Staff Report. Comment [A215]: The annual report provision

was relocated from PAR 353.O.4 to a stand

- alone section per an Industry suggestion.

Comment [A216]: Added to clarify that Rule 321 provisions apply to solvent cleaning machines when used in conjunction with applying adhesives

and sealants.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page H-1 June 21, 2012

Santa Barbara County APCD Appendix H Santa Barbara County Identification of Existing Federal Regulations and Air Pollution Control District Regulations that Apply to the Same Equipment or Source Ty pe Covered in Rules 330, 337, 349, and 351

This appendix is provided to comply with the Califo rnia Health & Safety Code Section 40727.2 requirements.

Federal Air Pollution Control Requirements

The federal requirements in the below-referenced statutes apply to the same equipment or source types covered by Rules 330, 337, 349, and 351:

x 40 CFR, Part 60, Section 60.310 et seq. , Subpart EE, Standards of Performance for Surface Coating of Metal Furniture. (Rule 330)

x 40 CFR, Part 60, Section 60.440 et seq. , Subpart SS, Standards of Performance for Industrial Surface Coating: Large Appliances. (Rule 330)

x 40 CFR, Part 60, Section 60.460 et seq. , Subpart TT, Standards of Performance for Metal Coil Surface Coating. (Rule 330)

x 40 CFR, Part 60, Section 60.490 et seq. , Subpart WW, Standards of Performance for the Beverage Can Surface Coating Industry. (Rule 330)

x 40 CFR, Part 63, Section 63.3480 et seq. , Subpart KKKK, National Emission Standards for Hazardous Air Pollutants: Surface Coating of Metal Cans. (Rule 330)

x 40 CFR, Part 63, Subpart MMMM, Section 63.3880 et seq. , National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products. (Rule 330)

x 40 CFR, Part 63, Subpart NNNN, Section 63.4080 et seq. , National Emission Standards for Hazardous Air Pollutants: Surface Coating of Large Appliances. (Rule 330)

x 40 CFR, Part 63, Subpart RRRR, Section 63.4880 et seq. , National Emission Standards for Hazardous Air Pollutants: Surface Coating of Metal Furniture. (Rule 330)

x 40 CFR, Part 63, Subpart SSSS, Section 63.5080 et seq. , National Emission Standards for Hazardous Air Pollutants: Surface Coating of Metal Coil. (Rule 330)

x 40 CFR, Part 63, Subpart GG, Section 63.741 et seq. , National Emission Standards for Aerospace Manufacturing and Rework Facilities. (Rule 337)

x 40 CFR, Part 63, Subpart HHHHHH, Section 63.11169 et seq. , National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Su rface Coating Operations at Area Sources. (Rules 330 and 337)

x 40 CFR, Part 63, Subpart XXXXXX, Section 63.11514 et seq. , National Emission Standards for Hazardous

Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. (Rules 330 and 337)

x 40 CFR, Part 63, Subpart VVVV, Section 63.5680 et seq. , National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing. (Rules 349 and 353)

x 40 CFR, Part 63, Section 63.5780 et seq. , Subpart WWWW, National Emission Standards for Hazardous Air Pollutants: Reinforced Plastic Component Production. (Rule 349)

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page H-2 June 21, 2012

Santa Barbara County APCD Santa Barbara County Air Pollution Control District Requirements

These are shown in the following table.

Table 1. RULES THAT APPLY TO THE SAME EQUIPMENT TYPES THAT ARE SUBJECT TO RULES 330, 337, 349, AND 353

GENERIC REQUIREMENTS AFFECTED EMISSION

UNITS BASIS FOR APPLICABILITY

R ULE 

### 201 : Permits Required All emission units Emission of pollutants

R ULE 

### 202 : Exemptions to Rule 201 Applicable emission units Insignificant activities/emissions, per size/rating/function

R ULE 

### 210 : Fees All emission units Administrative

R ULE 

### 212 : Emission Statements All emission units Administrative

R ULE 

### 302 : Visible Emissions All emission units Particulate matter emissions

R ULE 

### 303 : Nuisance All emission units Emissions that can injure, damage, or offend.

R ULE 

### 317 : Organic Solvents All emission units Emission of pollutants

R ULE 

### 322 : Metal Surface Coating

Thinner and Reducer All emission units Composition of organics in all metal surface coating thinners

and reducers shall not be photochemically reactive

R ULE 

### 324 : Disposal and Evaporation of Solvents All emission units Solvent disposal requirements

R EGULATION 

### VIII : New Source

Review All emission units Addition of new equipment or modification to existing equipment. Applications to generate ERC Certificates.

R EGULATION 

### XIII (R ULES 

### 1301- 1305) : Part 70 Operating Permits All emission units A stationary source is a major

source.

A review of Table 1 indicates that there are no overlapping or conflicting averaging provisions, units, or any other pertinent provisions associated with emission limits.

Click here to return to the list of Appendices in the Staff Report.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-1 June 21, 2012

Santa Barbara County APCD Appendix I Santa Barbara County

Clarification of Rule Issues

The District worked closely with the regulated community to develop specific approaches to their individual needs and to clarify rule text. As a result of these efforts, staff received extensive feedback and input during the development stages. Also, members of the regulated communi ty raised questions about the intent of certain rule provisions through discussion s with staff and at the rule development public workshops.

The following text provides clarification of ru le issues and consolidates comments/responses. a 

### To help readers locate a specific issue, a table of contents is provided below.

Table 1. CLARIFICATION OF RULE ISSUES TABLE OF CONTENTS

Item Rule Section Topic Page

1 330.A, 337.A, 349.A, and

353.A Scope of new solvent requirements. I- 2

2 330.C, 337.C, 349.C, and

353.C Consistency of definitions. I- 2

3 330.D and 337.D Conformal coating ROC-content limits. I- 3

4 330.F.3, 337.F.3, 349.D.3.c,

and 353.J.3 Waste disposal methods. I- 3

5 330.F.7, 337.F.7, 349.D.3.g,

and 353.J.7 Waste drum labeling or marking requirement. I- 3

6 330.H.1.d, 337.H.1.d, 349.F.1.d, and 353.O.1.d Using manufacturer’s recommended mixing data to comply with the recordkeeping provision I- 3

7 330.H.8, 337.H.6, 349.F.7,

& 353.O.6 Record retention period and meaning of “readily available.” I- 3

8 330.I.1, 337.I.1, 349.E.5,

and 353.N.1 Methods for determining a coating or a solvent’s ROC content. I- 4

9 330.J, 337.D.2, 337.J, 349.H, 353.G, 353.H, and

353.R Do toluene, acetone, methanol, isopropanol, and methyl ethyl ketone comply with the new rule provisions? I- 4

10 330.J, 337.J.1.b, 349.H, and

353.G.2 Acceptable methods for cleaning spray guns. I- 5

11 330.M, 337.M, 349.J, and

353.T Use of wash stations to clean application equipment and/or use of solvent cleaning machines to cl ean parts prior to painting. I- 6

12 337 Add aerospace vehicle and comp onent adhesive and sealant provisions to Rule 337. I- 6

13 337.A Aerospace ground support equipment provisions. I- 6

14 337.B.7 Satellite coating application equipment cleaning exemption. I- 7

15 337.C Rule 321 and 337 definitions of aerospace vehicle or
component are different. I- 7

16 337.C Adhesive primer vs. adhesive bonding primer definitions. I- 8

17 337.D.1 Meaning of the word "new" fo r the "new commercial aircraft"

limit in Table 337-2. I- 8

18 337.D.1 Rule 337 adhesive limits for aerospace vehicles and components. I- 8

19 337.D.1 Rule 337 coating categories and limits. I- 9

20 337.D.1 Stealth aircraft coating limits. I- 9

a 

### Comments received during the formal public comment pe riod preceding the Board adoption hearing on the proposed rule changes, and staff’s response to these comments, will be presented to t he District Boa rd of Directors as part of the rule adoption process.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-2 June 21, 2012

Santa Barbara County APCD Item Rule Section Topic Page

21 337.D.2, 337.J.1.a, 353.G.1,

and 353.R Debonding and reworking parts that have been glued. I- 9

22 337.J.1.b Using high ROC-content solven ts when cleaning aerospace coatings from application equipment. I- 10

23 337.J.1.b and 353.G.2 Option to use an enclosed cleaning system for cleaning application equipment in lieu of using low-ROC solvents. I- 10

24 337.J.1.b and 353.G.2 Solvent cleaning of application equipment with an enclosed cleaning system. I- 10

25 337.J.1.b and 353.G.2 Definition of an enclosed cleaning system

. I- 10

26 353.A Rule 353 applicability when a source applies aerospace vehicle and component adhesives. I- 11

27 353.B.13.i Exemption for avionic equipment. I- 11

28 353.G.1 What surfaces are included in the requirements for cleanup solvent and/or cleanup method? I- 12

29 353.G.2 Requiring use of low ROC content solvent or an enclosed gun washer when cleaning application equipment. I- 12

30 202.D.14 & 202.D.10.l.2 Architectural coating permit exemption vs. the tertiary-butyl acetate one gallon per year per stationary sourc e permit exemption I- 12

31

- Sources for solvent ROC and toxic air contaminant data I- 13

1. Scope of new solvent requiremen ts (330.A, 337.A, 349.A, and 353.A).

Question/Issue: Will the proposed amended rules limit the solvent ROC-content for solvents used in stripping, thinning, or solvent welding?

Answer/Response: The rule modifications include adding new solvent cleaning provisions. No changes to the ROC contents of thinning solvents or solvents used in solvent welding are propos ed. A slightly lower ROC content for strippers subject to Rules 337 or 353 is bein g proposed in response to an ARB comment. Additional

information for each of these ca tegories is provided below:

Thinning: The rules limit the coating an d polyester resin material usage on an as applied basis. Sources will be able to continue to thin materials with solvents providing they comply with the as applied limits in the applicable rule.

Stripping: The Rule 337 stripper ROC-content limit is being reduced from 400 to 300 grams per liter. Also, we added stripping provisions to Rule 353 to addres s debonding/unglueing issues on cured adhesives.

Solvent Welding: Welding adhesive limits in Rule 353 apply to 3 types of plastic: ABS, CPVC, and PVC.

2. Consistency of definitions (330.C, 337.C, 349.C, and 353.C).

Question/Issue: Industry requests that there be consiste ncy in the definitions between the different rules. For example, some rules have a definition of touch-up and others don't.

Answer/Response: The District strives for consistency of definitions across the rules. In some cases, the inconsistencies are intentional (e.g., the Rule 321 an d Rule 337 definitions relative to aerospace vehicles and aerospace vehicle components). Staff generally proposes definitions found in ARB or EPA guidance

documents or state or federal law.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-3 June 21, 2012

Santa Barbara County APCD Regarding the touch-up

, touch-up coatings, and touch-up and repair definitions, these vary from rule to rule due to the different operations. Th e Rule 330.B.2 exemption uses the term touch-up coatings ; Rule 330.C’s definition of this term is consistent with the one found in the metal parts coating Control Techniques Guidelines (CTG). Rule 337.B.2 exemption uses the term touch-up and repair , which is based on the aerospace CTG’s touch-up and repair operation definition. Rule 337.B.11 exemptions use the term touch-up , which stems from the 40 CFR Section 63.747(c)(3)(i) and (ii) exemptions.

3. Conformal coating ROC-content limits (330.D and 337.D).

Question/Issue: Is the application of conformal coatings covered by Rule 330, 337, or neither of those rules?

Answer/Response: Neither of those rules. Rule 330 applies to metal parts and products. The application of conformal coatings to electr onic components is exempt by Rule 330.B.4. Under proposed amended Rule 337

definition of aerospace vehicle or component , electronic components are excluded . A person using solvent in association with applying a conformal coating is subject to Rule 321 provisions.

4. Waste disposal methods (330.F.3, 337.F3, 349.D.3.c, and 353.J.3)

Question/Issue: Are owners and operators allowed to comingle their wastes?

Answer/Response: Yes, provided the wastes are disposed of by methods specified in the rule:

1. A commercial waste solvent reclamation service licensed by the State of California. 2. At a facility that is federally or state licensed to treat, store or di spose of such waste. 3. Recycling in conformance with Section 25143.2 of the California Health and Safety Code.

5. Waste drum labeling or marking requirement (330.F.7, 337.F.7, 349.D.3.g, and 353.J.7)

Question/Issue: How much detailed information needs to be on secondary containers; for example, do we need to specify the materials ROC content?

Answer/Response: No, the owner or operator needs to only specify generically what material is in the container. For example, the drum’s markings could show, “mixed was te paints, solvents, an d strippers.” There is no need to specify the material ’ s density or ROC content.

6. Using manufacturer’s recommended mixing data to comply with the recordkeeping provision (330.H.1.d, 337.H.1.d, 349.F.1.d, and 353.O.1.d)

Question/Issue: My source mixes paints, adhesives, and epoxies following the manufacturer s’ recommended amounts for each component and the manufacturers provide the “as applied” ROC content data for the mixed products. Will maintain ing the manufacturer’s mixing data meet the rule requirements on recording specific mixing data for each batch?

Answer/Response: Yes, provided the manufacturer’s recommended mixing procedures are followed.

7. Record retention period and meaning of “readily available” (330.H.8, 337.H.6, 349.F.7, and 353.O.6)

Question/Issue: Are owners and operators requir ed to keep records longer than 2 years?

Answer/Response: It depends; records need to be maintained for 5 years if a source is subject to:

1. Rule 370, Potential to Emit - Limitations for Part 70 Sources, or 2. Rule 1301, Part 70 Operating Permits - General Information, or

3. A MACT standard.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-4 June 21, 2012

Santa Barbara County APCD Question/Issue: Please explain what “readily available” me ans. We have a large stationary source with numerous facilities and records are not kept at each facility’s site.

Answer/Response: We consider “readily available” to mean the records can be provided within twenty-four hours after receiving a District re quest to inspect and review them.

8. Methods for determining a coating or a solvent's ROC content

Question/Issue: Will the District require that a source have a U.S.EPA Method 24 test done to determine the ROC content of a coating or a solvent or will the VO C data from a material safety data sheet (MSDS) be

sufficient?

Answer/Response: Ideally, coating and solvent manufacturers base their product’s VOC grams per liter data on

a U.S.EPA Method 24 test. For solven ts comprised of one chemical, the product’s ROC content equals its density (assuming it is not an “exempt compound”). MSDS reported VOC concentration data may be acceptable. However, in certain cases the District ma y require a source to have an independent laboratory perform a U.S.EPA Me thod 24 test to determine a product’s VOC content.

9. Do toluene, acetone, methanol, isopropanol, and me thyl ethyl ketone comply with the new rule provisions (330.J, 337.D.2, 337.J, 349.H, 353.G, 353.H, and 353.R)?

Question/Issue: Our company wipe cleans electronic parts and products using TAMI solvents before applying surface coatings. TAMI solvents incl ude toluene, acetone, methanol, and is opropanol (isopropyl alcohol, IPA) solvents. Will we be able to continue using the TAMI solvents under the proposed amended rules? What about the use of methyl ethyl ketone (MEK) solvent?

Answer/Response: It depends on the type of produ ct being cleaned, the purpose of the cleaning, and the applicable rule. If the product cleaning is not associated with a Rule 330, 337, or 353-type surface coating or a Rule 349 polyester resin operation, then Rule 321 applies. In general, the answer is:

1. no, TAMI and MEK solvents cannot be used if the operation is subject to a new solvent provision prohibiting the use of high ROC-content solvents, and 2. yes, if the operation is exempt from the rule ’s solvent cleaning provision, the operation is not within the rule's applicability, or the rule requirements are su ch that the solvent complies (e.g., Rule 337 limits of 200 g/l or 45 mm of Hg).

The only cleaning compound used in the TAMI-MEK group that complies with the proposed amended rules’

ROC-content limits is acetone. Acetone is technically not a “ solvent, ” as the term is used in Rule 321 and the proposed amended rules; it contains no ROCs and no to xic air contaminants. Tolu ene and isopropanol meet the ROC composite partial pressure limit of PAR 337.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-5 June 21, 2012

Santa Barbara County APCD This table shows the TAMI and MEK cleaning material ROC data and the rule limits:

Solvent Solvent ROC

Content (grams per

liter aka g/l) Rule 330, 349, and 353

Solvent ROC

Content Limit (g/l) Rule 337

Solvent ROC

Content Limit (g/l) Solvent ROC

Co mposite

Partial Pressure (mm Hg at 20 ° C) Rule 337 Solvent ROC Composite

Partial Pressure Limit (mm Hg at 20 ° C)

Toluene 866 25 200 21.86 45

Acetone a 

### 0 25 200 0 45

Methanol 799 25 200 97 45 Isopropanol 785 25 200 32.8 45 Methyl Ethyl

Ketone 809 25 200 78 45

The following summarizes the solvent c leaning/stripping ROC content and/or composite partial pressure limits in each of the proposed amended rules.

Rule 330 Surface preparation and clea ning of application equipment: 25 g/l. Surface coating operations and associated solvents used on electronic components may be exempt by Rule 330.B.4 or B.11.

Rule 337 Surface preparation: 200 g/l or 45 mm of Hg at 20 degrees C; stripper: 300 g/l or 9.5 mm of Hg at 20 degrees Celsius; application equi pment cleaning: 25 g/l or use of an enclosed cleaning system. Per

the Rule 337 aerospace vehicle or component definition, Rule 337 does not apply to electronic components. Exemptions in PAR 337.B.9 may apply to ancillary electronic equipment.

Rule 349 Product cleaning, surface preparation, repair & maintenance cleaning, and application equipment cleaning: 25 g/l. Solvent cleaning of electronics are like ly exempt by Sections B.4.a, b, c, or f or Section

B.5.

Rule 353 Surface preparation and cleanup solvent: 25 g/l; stripper: 300 g/l or 9.5 mm of Hg at 20 degrees Celsius. The cleaning of electronic parts may be exempt by Rule 353.B.13.

10. Acceptable methods for cleaning spray guns (330.J, 337.J.1.b, 349.H, and 353.G.2).

Question/Issue: What are the acceptable methods for cleaning spray guns under the proposed amended rules?

Answer/Response: These vary depending on the rule as shown in the following table.

Rule Solvent ROC

Content Limit Alternative Compliance Methods (one of the following, as allowed)

Use of Add-On Control Equipment Use of an Enclosed Cleaning System b



### 330 25 Allowed Not an alternative compliance option c



### 337 25 Allowed Allowed

349 25 Allowed Not an alternative compliance option a



### 353 25 Allowed Allowed

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a 

### “Acetone” is technically not a solvent.

b 

### Item 25 discusses the definition of an “enclosed cleaning system.”

c 

### See item 23 for more information.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-6 June 21, 2012

Santa Barbara County APCD Question/Issue: What if my source uses acetone to clean spray guns?

Answer/Response: Acetone is technically not considered to be a solvent as the compound contains no reactive organic compounds or toxic air contaminants. Hence, no District rule requirements apply to cleaning of application equipment with acetone. It should be noted that acetone is flammable and other agency requirements likely apply.

11. Use of wash stations to clean application equipment and/or use of solvent cleaning ma chines to clean parts prior to painting (330.M, 337.M, 349.J, and 353.T).

Question/Issue: We use solvent wash stations that ha ve capacities greater than 1 gallon to clean application equipment. Will this activity be allowed under the proposed amended rules?

Answer/Response: Yes, provided th e equipment and its operation comply with the provisions of Rule 321. "Wash stations" are considered to be "cold cleaning machin es." All solvent cleaning machines should comply with Rule 321 regardless of an overall process being subj ect to an operation-specific rule (e.g., Rules 330, 337, 349, or 353). To clarify this issue, the District is proposing:

1. a minor Rule 321.B.6 revision, 2. changes to PARs 330, 337, 349, and 353 to:

a) expand the definition of “associated solvent” to include “solvent cleaning machines,” b) add a definition of “solvent cleaning machine,” and c) include new sections at the end of each rule that indicate:

Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solven t cleaning machine shall comply with the applicable provisions of Rule 321, Solvent Cleaning Machines and Solvent Cleaning.

Question/Issue: We paint metal parts that are subject to Rule 330. Immediately before painting them, we surface prep them using a solvent c leaning machine (degreaser). Is this allowed under the proposed amended

rule?

Answer/Response: Yes, provided th e equipment and its operation comply with the provisions of Rule 321. For further details, see the prev ious answer/response.

12. Add aerospace vehicle and component adhesive and sealant provisions to Rule 337 (337).

Question/Issue: Aerospace vehicle and component adhesive requirements should be in Rule 337.

Answer/Response: We agree and have added these provis ions to Rule 337. This is consistent with the EPA Control Techniques Guidelines for Coating Operations at Aero space Manufacturing and Rework Operations.

13. Aerospace ground support equipment provisions (337.A).

Question/Issue: Satellite ground support equipment is some times refurbished (e.g., removal and replacement of insulation). The Rule 337 exemption provisions should ex tend to the ground support equipment due to the need to maintain certain levels of cleanliness during the transportation and handling of satellites.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-7 June 21, 2012

Santa Barbara County APCD Answer/Response: We concur and have incl uded the following exemptions and definition.

PAR 337.B.7 Exemption:

Section D.2 and J.1.a shall not apply to solvents and strippers used in space vehicle manufacturing and

rework.

PAR 337.B.9.g Exemption:

Section J.1.a shall not apply to wipe cleaning of aircr aft and ground support equipment fluid systems that are exposed to the fluid, including air-to-air heat exchangers and hydraulic fluid systems.

PAR 102 Definition:

“Space Vehicle” means any man -made device, either manned or unmanned, designed for operation beyond earth's atmosphere. This definition includes integr al equipment such as models, mock-ups, prototypes, molds, jigs, tooling, hardware jackets, and test cou pons. Also included is auxiliary equipment associated with test, transport, and storage, which throu gh contamination can compromise the space vehicle performance.

The District modeled the Rule 102 space vehicle definition on the 40 CFR Part 63, Subpart GG term.

For surface coating operations on ground support equipm ent not associated with spac e vehicles, the provisions of Rule 339, Motor Vehicle and Mobile Equipment Coating Operations, may apply. Ab lative coatings on space vehicle launch pad equipment and structures are subject to Rule 337 provisions.

14. Satellite coating application equipmen t cleaning exemption (337.B.7).

Question/Issue: There are overlapping provisions between Rule 321 and Rule 337 regarding satellite coating operations. Specifically, Rule 321.B.10 exempts th e cleaning of application equipment associated with applying satellite coatings. Since satell ite coating operations are covered in Rule 337, this exemption seems out of place.

Answer/Response: The District concurs and plans to d elete the Rule 321.B.10 text relative to applying coatings on satellites in a future rulemaking effort. It should be noted that proposed amended Rule 337.B.7 provides exemptions for satellite stripping and su rface preparation (337.D.2 and J.1.a). However, per PAR 337.J.1.b, satellite coating application equipment cleaning will require eith er 1) a solvent with an ROC content 25 g/l or less, or 2) an enclosed cleaning system.

15. Rule 321 and 337 definitions of aerospace vehicle or component are different (337.C).

Question/Issue: The Rule 337 definition of aerospace ve hicle or component excludes electronic components. But the Rule 321 definitions of aerospace vehicle and aerospace vehicle componen t do not exclude electronic components. Are these differences between the Rule 321 and Rule 337 definitions intentional?

Answer/Response: Yes, our approach is to make the provisions of Rule 321 applicable to electronic components used in aerospace ve hicles and aerospace vehicle compon ents. Electronic component coating operations are not subject to Rule 337, which is consistent with the provisions in 40 CFR Part 63, Subpart GG.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-8 June 21, 2012

Santa Barbara County APCD 16. Adhesive primer vs. adhesive bonding primer definitions (337.C).

Question/Issue: In Rule 337, what's the difference be tween adhesive primer (as defined in the compatible substrate primer definition) and adhesive bonding primer?

Answer/Response: These terms stem from 40 CFR 63, Su bpart GG and we defer to EPA for an explanation on

their differences.

“Adhesive Bonding Primer” means a prim er applied in a thin film to ae rospace components for the purpose

of corrosion inhibition and increased adhesive bond strength by attachment. There are two categories of adhesive bonding primers: primers with a design cure at 250°F or below and primers with a design cure

above 250°F.

“Compatible Substrate Primer” includes two categor ies: “compatible epoxy primer” and “adhesive primer.” [. . .] “Adhesive primer” is a coating that (1) inhibits corrosion an d serves as a primer applied to bare metal surfaces or prior to adhesi ve application, or (2) is applied to surfaces that can be expected to contain fuel. Fuel tank coatings are excluded from this category.

17. Meaning of the word "new" for the "new co mmercial aircraft" limit in Table 337-2 (337.D.1).

Question/Issue: Rule 337 has a category for new comm ercial aircraft under adhesive bonding primer. What constitutes a new aircraft part or product?

Answer/Response: If an aircraft part or product is currently undergoing construction/assembly or has been recently made (e.g., within the last three months) or has not yet been used, it will be considered to be new.

18. Rule 337 adhesive limits for aerospace vehicles and components (337.D.1).

Question/Issue: What are the propos ed adhesive limits in Rule 337?

Answer/Response: They are found in proposed am ended Rule 337, Section D.1, Table 337-2 for specialty coatings (Staff Report ’s Appendix E ). The District included adhesive categories from the 1997 Control Techniques Guideline, "Surface Co ating Operations at Aerospace Manufact uring Rework Operations." Staff also included a few adhesive categories from the SJV, SC, and VC rules.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-9 June 21, 2012

Santa Barbara County APCD 19. Rule 337 coating categories and limits (337.D.1).

Question/Issue: For proposed amended Rule 337, why we re coating types added, what existing limits were changed, and what was the basis for the change?

Answer/Response: The need to add coating types stems from the state requirement to include every feasible control measures. The District is using the EPA guid ance on meeting the presumptive reasonably available control technology requirements to meet California's ev ery feasible measures requirement. The District used the 1997 Control Techniques Guideline, "Surface Coating Operations at Aerospace Manufacturing Rework Operations," to determine the coating types that should be added. Staff also used some of the general categories from the National Emission Standards for Hazardous Air pollutants (NESHAP) for the source type: 40CFR63, Subpart GG.

The annotated proposed amended Rule 337 (Staff Report ’s Appendix E) shows the existing limits that were changed in strikeout and underline format. This anno tated rule also includes notes on the basis for coating

limits.

In general, staff compared the limits in the CTG and NESHAP to those in existing Rule 337 and other air districts. Lower ROC-content limits that have been achieved in practice were included in lieu of the limits

recommended in the CTG or NESHAP.

20. Stealth aircraft coating limits (337.D.1).

Question/Issue: What is the ROC-content limit for aircr aft coatings that prevent the transmission of light?

Answer/Response: PAR 337's definition of electric- or radiation-effect coating incl udes coatings that interact through absorption or reflection of light. The Table 337-2 limit for this category is 800 g/l. If the U.S. Dept. of Defense has designated an electric- or radiation-effect co ating as classified, such coating is exempt from the Table 337-2 limit per Rule 337.B.12.

21. Debonding and reworking parts that have been glued (337.D.2, 337.J.1.a, 353.G.1, and 353.R).

Question/Issue: Reworking parts that are being glued toge ther requires special cons ideration. The process may involve cured or uncured adhesives. It overlaps th e Rule 353 surface preparation and cleanup provisions.

Answer/Response: The District agre es and has taken the following steps to clarify the requirements when reworking parts that have uncured or cured adhesives:

1. A definition of stripper is added to Rules 337 and 353, which indicates:

“Stripper” means any liquid that is applied to a surface to remove cured or dried coatings primers, adhesives (e.g., debonding or unglueing), topcoats, and temporary protective coatings.

2. Adhesive provisions were added to Rule 337.

3. Section R was added to Rule 353, which is similar to the Rule 337.D.2 stripper use provisions.

Under the proposed amended rules, removal of uncured adhesives will be subject to either 337.J.1.a (200 g/l or less ROC content or a solvent with an ROC composite par tial pressure of 45 mm of Hg at 20 degrees C or less) or Rule 353.G.1 (to become 25 g/l or ROC or less) depending on the source type.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-10 June 21, 2012

Santa Barbara County APCD For removal of cured or dried adhesives (use of a stripper), Rule 337.D.2 or Rule 353.R will apply, depending on the source type. Both of these provisions are the same: 300 g/l or less ROC content or a solvent with an ROC composite partial pressure of 9.5 mm of Hg at 20 degrees C or less.

22. Using high ROC-content solvents when cleaning ae rospace coatings from app lication equipment (337.J.1.b).

Question/Issue: Cleaning application equipment that app lies epoxy polyamide topcoats to satellites requires a high ROC-content solvent (900 g/l). Will this be allowed under the proposed amended rules?

Answer/Response: Yes, provided an enclosed cleaning system is employed.

23. Option to use an enclosed cleaning system for cleaning application equipment in lieu of using low-ROC solvents (337.J.1.b and 353.G.2).

Question/Issue: Proposed amended Rules 337 and 353 allow the option of using an enclosed cleaning system when cleaning application equipment. However, Rules 330 and 349 do not include this option. Was this

intentional?

Answer/Response: Yes, we followed the same approach used in other air districts. Sources subject to Rule 330 and 349 using enclosed cleaning systems need to ensure th e solvent ROC content does not exceed 25 grams per

liter.

24. Solvent cleaning of application eq uipment with an enclosed cleaning system (337.J.1.b and 353.G.2).

Question/Issue: Is an enclosed cleaning system for cleaning application equipment a solvent cleaning

machine ?

Answer/Response: No, unless a source is using an airless solvent cleanin g machine or an air-tight solvent cleaning machine exclusively for cleaning application equi pment. Airless and air-tight solvent cleaning machines are designed to remove th e air inside the chamber before solv ent is introduced into the cleaning

chamber. Due to cost considerations , it is unlikely that a source would use an airless or air-tight solvent cleaning machine for cleaning application equipment.

25. Definition for enclosed cleaning system (337.J.1.b and 353.G.2).

Question/Issue: What constitutes an enclosed cleaning system for cleaning application equipment?

Answer/Response: The District added the following definition to Rule 102:

“Enclosed Cleaning System” means any application equipment cleaner (e.g., an enclosed gun washer) that totally encloses spray guns, cups, nozzles, bowls, and other parts du ring solvent washing, rinsing, and draining procedures. An enclosed cleaning system for cleaning application equipment is not a solvent cleaning machine.

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### STAFF REPORT

– PARs 330, 337, 349, & 353 Page I-11 June 21, 2012

Santa Barbara County APCD 26. Rule 353 applicability when a sour ce applies aerospace vehicle and component adhesives (353.A).

Question/Issue: Is the use of adhesives on aerospace vehicles and components exempt from Rule 353 per

Section B.1.f.1?

Answer/Response: Yes, and the proposed amended ru le changes are intended to make the Rule 353.B.1.f.1 exemption less ambiguous. The legislative intent of exis ting Rule 353.B.1.f.a text was to exempt aerospace adhesives from Rule 353. Per the August 19, 1999 Rule 353 Board Package response to Public Comment

number 1-2:

The District amended Section B.1.f to list the adhesi ves and sealants that are exempt from Rule 353 because they are subject to Rule 337, Surface Coating of Aircraft or Aerospace Vehicle Parts and Products, or Rule 354, Graphic Arts.

C&D Aerospace, an aircraft refurbishing facility, uses adhesives and sealants. Section B.1.f of Rule 353 exempts C&D Aerospace’s adhesive and sealant oper ations from Rule 353. These adhesive and sealant operations are subject to Rule 337.

The District initially believed some portions of operatio ns at C&D Aerospace and The Jet Center @ Santa Barbara would be subject to Rule 353. However, af ter further analyses, we decided that aircraft and aerospace glues are highly specialized and should be regulated through Rule 337.

Also, the response to Public Comment number 1- 10 from this same document indicates in part:

C&D Aerospace adhesive and sealant applications are su bject to Rule 337 and they are exempt from Rule 353 by Section B.1.f.

27. Exemption for avionic equipment (353.B.13.i).

Question/Issue: Why is avionic equi pment included in the Rule 353.B.13.i exemption from Section G.1, H, and

R?

Answer/Response: Without this exemption, avio nic equipment would be subject to those Rule 353 solvent/stripping provisions.

Per the definition of aerospace vehicle or component , Rule 337 does not apply to electronic components. Rule 353.B.5.a exempts adhesives/sealants and associated solvents that are subject to Rule 337. Since Rule 337 does not apply to aerospace vehicle elec tronic components, the Rule 353.B.5.i exemption does not apply to such electronic components.

The District recognizes the need for maintaining a higher degree of cleanliness for avionic equipment (and other items identified in 353.B.13.i). Therefore, we have added a limited exemption fo r surface preparation, cleanup, and stripping operations associated with avionic equipment in Rule 353.

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Santa Barbara County APCD 28. What surfaces are included in the requirements for cleanu p solvent and/or cleanup method (353.G.1)?

Question/Issue: Please clarify the meaning of the term surfaces in the current Rule 353.G.1 provision:

Except as provided in Section I of this rule, no person shall use materials containing reactive organic compound for the removal of adhesives, adhesive bon ding primers, adhesive primers, sealants, sealant primers, or any other primer from surfaces, other than spray application equipment, unless the reactive organic compound composite partial pressure of the solvent used is less than 45 millimeters (mm) of mercury (Hg) at 20 degrees (°) Celsius (C).

Does this provision apply to only solvent used to clean work surfaces?

Answer/Response: No, the provisio n applies to cleanup of any surface (e.g., product surfaces, jigs, clamps, benches, and any other work surfaces after adhesive has been applied), but not to so lvents used to clean spray application equipment. Cleaning of product surfaces before the application of adhesives is subject to 353.H. If a source subject to Rule 353 is cleaning uncured adhesi ves from parts in a rework activity, then the Rule 353.G.1 provisions apply. If the adhesive has cured (dry to the touch), then the removal of the adhesive is part of a stripping operation and the new 353.R provisions apply.

29. Requiring use of low ROC content solvent or an enclosed gun washer when cleaning application equipment (353.G.2).

Question/Issue: What are the costs associated with re quiring a non-ROC solvent or an enclosed cleaning system in lieu of using a solvent wash station for cleaning application equipment?

Answer/Response: The cost of an enclosed cleaning system ranges between $500 and $2,800 for an automated system. If an existing wash station has MEK solvent and acetone is used instead, ther e will be a solvent costs savings. IPA and acetone solven t costs are about the same.

A wash station employed with acetone is not subject to Rule 321 because acetone is technically not classified as a solvent. Hence, a source could forgo enclosed gu n washer costs or solvent cleaning machine modification costs if acetone is employed.

30. Architectural coating permit exemption vs. the tertiary-buty l acetate one gallon per year per stationary source permit exemption (202.D.14 & 202.D.10.l.2)

Question/Issue: Bridge painting is permit-exempt by Rule 202.D.14. However, if the bridge coating materials contain tertiary-butyl acetate (tBAc) and tBAc use is in excess of one gallon, does Rule 202.D.10.l.2 require that the painting operation be permitted?

Answer/Response: It depends; painting with materials wh ere tBAc use exceeds 1 gallon per year per stationary source will trigger a permit if the bridge pain ted is part of a stationary source. Rule 202.D. 10.l indicates, “. . . notwithstanding any exemption defined in this rule, no new or modified stationary source . . .” Thus, D.10.l.2 overrides the D.14 provision and a permit is required if the bridge is part of a stationary source. Otherwise, Rule 202.D.10.l is not applicable and the ope ration is exempt by Rule 202.D.14.

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– PARs 330, 337, 349, & 353 Page I-13 June 21, 2012

Santa Barbara County APCD 31. Sources for solvent ROC and toxic air contaminant data

Question/Issue: Where can I find data on a particular solvent’s ROC content and toxic air contaminant (TAC) classification?

Answer/Response: The District has summarized data on many solvents. To access this data, download the Rule 321 Staff Report from this link: www.sbcapcd.org/apcd/boardfiles/9-10-R321-BL.pdf . ROC and TAC data is shown in the Staff Report ’s Appendix N, Solvent Information Table, which begins on page 249 of the PDF file. All TAC compounds that had been classified as TACs as of September 2010 are shown in Appendix M, which begins on page 233 of the PDF.

Other sources of ROC/TAC data include material safety data sheets, product labels, and reference books.

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### PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT–PARs 330, 337, 349, & 353Page J-1June 21, 2012Santa Barbara County APCDAppendix JSanta Barbara CountyComparison of the Adjoining Air District Rulesthat Apply to the Same Equipment or Source Type Covered in Rules 330, 337, 349, and 351To navigate to theaerospace vehicles and components performance standardsclickhere(begins on page J-12), thepolyester resin operation performancestandardsclickhere(begins on page J-24), or theadhesive and sealant performance standardsclickhere(begins on page J-31).Surface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)General CoatingsBakedAir Dried275 g/l340 g/l275 g/l340 g/l275 g/l340 g/l275 g/l275 g/lMulti-Component no listed belowBakedAir Dried275 g/l340 g/lCamouflageBakedAir Dried360 g/l420 g/l360 g/l420 g/l360 g/l420 g/lElectric Insulating VarnishBakedAir Dried620 g/l620 g/l275 g/l420 g/lEtching FillerBakedAir Dried720 g/l720 g/l420 g/l420 g/lExtreme High GlossBakedAir Dried360 g/l420 g/l360 g/l420 g/lExtreme PerformanceBakedAir Dried360 g/l420 g/l360 g/l420 g/l275 g/l420 g/l360 g/l420 g/lHeat ResistantBakedAir Dried360 g/l420 g/l360 g/l420 g/l360 g/l420 g/lHigh GlossBakedAir Dried360 g/l420 g/lHigh Performance ArchitecturalBaked420 g/l720 g/l420 g/lSTAFF REPORT–PARs 330, 337, 349, & 353Page J-2June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)Air Dried420 g/l750 g/l420 g/lHigh TemperatureBakedAir Dried420 g/l420 g/l720 g/l720 g/l420 g/l420 g/lMetallic TopcoatBakedAir Dried360 g/l420 g/l360 g/l420 g/l360 g/l420 g/lMilitary SpecificationBakedAir Dried275 g/l420 g/lMold SealBakedAir Dried750 g/l750 g/l420 g/l420 g/lPan BakingBakedAir Dried420 g/l420 g/lPowder Coatings50 g/lPrefabricated ArchitecturalComponentBakedAir Dried275 g/l420 g/lPretreatment Wash PrimerBakedAir Dried420 g/l420 g/l780 g/l780 g/l275 g/l340 g/lRepairBakedAir Dried360 g/l420 g/l360 g/l420 g/lSilicone ReleaseBakedAir Dried420 g/l420 g/l420 g/l420 g/l420 g/l420 g/lSolar AbsorbentBakedAir Dried360 g/l420 g/l360 g/l420 g/l360 g/l420 g/lSolid Film LubricantBaked880 g/lSTAFF REPORT–PARs 330, 337, 349, & 353Page J-3June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)Air Dried880 g/lTouch-UpBakedAir Dried360 g/l420 g/l360 g/l420 g/lVacuum MetalizingBakedAir Dried800 g/l800 g/l420 g/l420 g/lZinc-Filled PrimersBakedAir Dried420 g/l420 g/lApplication EquipmentElectrostatic,electrodeposition, flow coat,roll coat, dip coat, HVLP,brush coat, continuous coat,hand application, or otherapproved methodthat candemonstrate at least 65%transfer efficiency.Electrostatic, flow coating,HVLP, or other approvedmethodthat can demonstrateat least 65% transferefficiency.Electrostatic, electrodeposition, flow coat, rollcoat, dip coat, HVLP, handapplication,detailing ortouch-up guns, or otherapproved methodthat candemonstrate at least 65%transfer efficiency.Electrostatic, flow coat, dipcoat, HVLP, handapplication, or otherapproved methodthat candemonstrate at least 65%transfer efficiency.Control EquipmentCapture and controlefficiency of 90%or greater.Use of the VOC emissioncontrol system shall notresult in emissions in excessof those that would havebeen emitted had theoperator complied withother applicable ruleprovisions.Control equipment shallresult in the same or greateremission reduction as wouldcompliance with the rule.Overall efficiency of 85.5%or greater. Use of the ROCemission control systemshall not result in emissionsin excess of those that wouldhave been emitted had theoperator complied withother applicable ruleprovisions.Capture and controlefficiency of90%or greater.Surface Preparation/CleanupSolventSurface preparation andcleanup solvents shall havean ROC content of 25 g/l orless.Closed containers.Solvents shall have an ROCcontent of 25g/l or less.(Becomes effective one-yearafter adoption of theamended rule.)Surface preparation andcleanup solvents shall havean ROC content of 25 g/l orless.STAFF REPORT–PARs 330, 337, 349, & 353Page J-4June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)Clean-Up Equipment, Cleaning ofApplication EquipmentSolvents shall have an ROCcontentof 25 g/l or less.Enclosed gun washer orequivalent APCO-approvedgun washer when using asolvent with a compositevapor pressure < 45 mm HGat 20 degrees C.Solvents shall have an ROCcontent of 25 g/l or less.(Becomes effective one-yearafter adoptionof theamended rule.)Solvents shall have an ROCcontent of 25 g/l or less.Evaporative Loss MinimizationClosed containers forstorage anddisposal ofsolvent soaked rags andpaper. Solvent containersmust be closed when not inuse. Minimize VOCcontaining materials spillsand clean-up spillsimmediately.Closed containers forstorage and disposal ofsolvent soaked rags andpaper. Solvent containersmust be closed when not inuse.Closed containers forstorage and disposal ofROC-containing materials(including cloth,paper,sand, etc.). ContainersforROC-contain materialsmustbe closed when not in use.Minimize ROC-containingmaterialspills and clean-upspills immediately.Disposeof wastes that contain ROCsby 1) a reclamation service,2) a facility that treats,stores, or disposes of suchwastes, or 3) recycling.Containers used to storeROC-containing materialsshall be marked or clearlylabeled indicating the nameof the material they contain.Closed containers forstorage anddisposal ofsolvent soaked rags andpaper. Solvent containersmust be closed when not inuse.RecordkeepingMaintain records of VOCcontents,mix ratios, coatingcategories used, coating andsolvent use records.Maintain daily records ofcoating and solvent use.Keep record when usingadd-on emission controlequipment.-Have coatingmanufacturer'sspecificationsheets, material safety datasheets (MSDS), or technicaldata sheets available forreview.-Maintain records showingthe amount and type ofcoatings and solvent used ona monthly basis, VOCcontent of coating and-Maintain a current file ofall ROC-containingmaterials that provides allinformation necessary toevaluate compliance,including: 1) material nameand manufacturer ID, 2)application method, 3)material type,typeoperation, and for liquidcoatings, the drying method-Maintain a current list of allcoatings that provides allinformation necessary toevaluate compliance,including: 1) the name andmanufacturer of eachcoatingandany catalystsand reducers used with eachcoating, 2) mix ratio ofcomponents used incoatings, 3) ROC content ofSTAFF REPORT–PARs 330, 337, 349, & 353Page J-5June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)solvents, applicationmethod, and amount ofsolvent disposed of or sentto a recycler.and equipment coated, 4)specificmixingvolumes ofeachcomponentsfor eachbatch, 5) correspondingROC contentlimit andasappliedROC content ofmaterials used, and 6)current manufacturer'sspecification sheets, materialsafety data sheets (MSDS),product data sheets,orairquality data sheets, whichlists the ROC content.available. Compliancewiththis provisionmay bedonebyensuring themanufacturer’sspecifications are listed onthe product container.-Maintain recordsfor eachROC-containing materialpurchased for use. Therecords shall include thefollowing: 1) material nameand manufacturerID, and 2)material type.-Maintain records of thedisposal methodeach timewaste solvent, waste solventresidue, or otherwastematerial that contains ROCsis removed for disposal.-Keep monthly records of:1)the volume of the ROCcontaining materials used, 2)ROC content of thematerials, and 3) resultingcoatings, as applied, and 4)coating category from §B.1of each coating used.-Maintain records whichshows the following for eachROC containing materialused for cleanup, includingequipment cleaning, andeach ROC containingmaterial used for substratesurface cleaning: 1) type,and 2)ROC content-Maintain records of themonthly volume of eachcomplyingcoating andsolvent used and dailyvolume of eachnoncompliant coatingsused.-When usingadd-onemission control equipment,maintaindaily recordsofkey system operating andmaintenance data.-All lists and records shallbe maintained for aminimum of 2 years fromthe date of entry and shall beavailable to the District.STAFF REPORT–PARs 330, 337, 349, & 353Page J-6June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)ROC emissions.-If claiming the §B.1orexemption, maintain: 1)dailyvolumes of noncomplyingcoatingsused byseparate formulation,and 2)annualrunning totals of noncomplyingcoating volumesused for each separateformulationand allformulations.-When usingadd-onemission control equipment,maintaindaily recordsofkey system operating andmaintenance data.-Maintain records for 2years unless otherwiserequired by state or federalregulations.Such recordsshall be available to theDistrict.Submittal of an Annual ReportSubmittal of an annualreport is required if aperson: 1) holds a permit forequipment subject to therule, or 2) a person is subjectto the rule and applies noncomplyingcoatings. Thereport is to include: 1)monthly records required by§H.5, 2) annual totals, 3) ifclaiming the §B.1exemption, the annual totalsof non-complying coatingsper §H.6.b, and 4) ifpermitted, the name andSTAFF REPORT–PARs 330, 337, 349, & 353Page J-7June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)address of the company oragency, and PTO number.Prohibition of SpecificationNo person shall solicit orrequire for use or specify theapplication of a coatingsubject to this rule if suchuse or application results ina violation of any of theprovisions of this rule. Theprohibition of this Sectionshall apply to all written ororalcontracts under theterms of which any coatingis to be applied to any metalpart or product at anyphysical location within theDistrict.A person shall not use,apply, or specify any coatingfor use on any metal part orproduct subject to theprovisions of this Regulationwhich contains volatileorganic compounds inexcess of the Section D.1limits, as applied.No person shall specify,solicit or require theapplication of any coating toany metal part or product, orthe use of anyequipmentcleaningsolvent, if suchapplication or use wouldviolate this rule. Thisprohibition applies to allwritten and oral contracts forwhich any coatingsubject tothis rule is to be applied toany metal part or product atany location in VenturaCounty.Coating Compliance Statement orLabeling RequirementsManufacturer of coatingsand solvents must provideVOC concentration, mixinginstructions, formulationinformation, andrecommendations regardingthinning, redacting, ormixing with any other VOCcontaining materials, andexpress the coating VOCcontent on an as appliedbasis when used inaccordance with themanufacturer'srecommendations.Manufacturer of coatingsand solvents must provideVOC concentration, mixinginstructions, formulationinformation, andrecommendations regardingthinning, redacting, ormixing with any other VOCcontaining materials, andexpress the coating VOCcontent on an as appliedbasis when used inaccordance with themanufacturer'srecommendations.Manufacturer of coatingsand solvents must provideVOC concentration, mixinginstructions, formulationinformation, andrecommendations regardingthinning, redacting, ormixing with any other VOCcontaining materials, andexpress the coating VOCcontent on an as appliedbasis when used inaccordance with themanufacturer'srecommendations.STAFF REPORT–PARs 330, 337, 349, & 353Page J-8June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)Liquid Cleaning MaterialCompliance Statement orLabeling RequirementsManufacturers of anysolvents subject to this ruleshall indicate on the solventcontainer, or on a separateproduct data sheet ormaterial safety data sheet,the name of the solvent,manufacturer's name, theVOC content, and density ofthe solvent, as supplied.The VOC content shall beexpressed in units ofgm/liter or lb/gallon.Manufacturer of liquidcleaning materials used incoating operations shalldesignate on product labelsor data sheets: 1) VOCcontent as supplied, 2)recommendations regardingmixing with any other VOCcontaining materials, and 3)VOC content when used inaccordance with themanufacturer'srecommendationExemptions-Okay to use noncompliantcoatings if usage is 55gallons per rolling,consecutive 365-day periodor less.-Rule does not apply to theapplication of coatings toaircraft, aerospace vehicles,marine vessels, can, coils,and magnetic wire andequipment subject to otherprohibitory rules (4602,4612, 4684).-The rule provisions do notapply to stripping of curedcoatings, cured adhesives,and cured inks, except thestripping of such materialsfrom spray applicationequipment.-The 25 g/l of VOC solventlimit does not apply to the 1)cleaning of solar cells, laser-Any coating used involumes of less than 20gallons in any calendar yearis exempt from the coatingVOC limit, provided that thesource demonstrates that nocomplying coatings areavailable. Written approvalmust be obtained from theDistrict.-Stationary sources usingnot more than four (4)gallons of paint, varnish,lacquer, thinner,and other solvent containingmaterials in any one daybased on a monthlyoperating dayaverage, provided therecordkeeping requirementsin Subsections E.1 and E.2of this Rule are satisfied.-Stationary sources electing-Any non-complyingcoatings withseparateformulation used in volumesof less than 20 gallons ofeachnon-complyingformulation per stationarysource in any calendar yearis exempt from the ROClimit. Coatings used foroperations that are exemptper Sections B.2, B.3, B.4,B.5, B.6,B.10, and B.12shall not be included incalculating the volume ofcoatings used under thisexemption. To qualify forthis exemption, the totalvolume of non-complyingcoatings at the stationarysourceshallnot exceed 55gallons annually.-The application method andrecordkeeping requirements- Coating limits do not applyif there is no complyingcoating available and totalusage of all noncomplyingcoatings has not exceeded55 gallons in any calendaryear.- This rule does not apply to:a. Aircraftor aerospacevehicle coating operationsb. Marine vessel exteriorsc. Motor vehicle and mobileequipment coating.d. Aerosol coating products.- The provisions of this rule,except Subsection B.8(Prohibition ofSpecifications), shall notapply to any stationarysource that emits less than200 pounds of ROC in everyrolling period of 12consecutive calendar monthsSTAFF REPORT–PARs 330, 337, 349, & 353Page J-9June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)hardware, scientificinstruments, or highprecision optics; 2) cleaningin laboratory tests andanalyses, or bench scale orresearch and developmentprojects; 3) cleaning ofpaper-based gaskets; and 4)cleaning of clutchassemblies where rubber isbonded to metal by means ofan adhesive.-The 25 g/l of VOC solventrequirement does not applyto the cleaning ofapplication equipment usedto apply 1) coatings onsatellites, or 2) radiationeffect coatings.to utilize control equipmentdemonstrated to thesatisfaction of the APCO toresult in the same or greateremission reduction as wouldcompliance with thisrule. Emissions, for thepurpose of this exemption,shall be calculated on anhourly basis.-The application equipmentrequirements do not applywhen a source candemonstrate to thesatisfaction of the APCOthat a transfer efficiency of65% cannot be achieved ormetallic coatings thatcontain more than 30 gramsof metal particles per literare used.do not apply to touch-up andrepairand texturecoatings,provided the ROC-contentlimits are met and recordsare maintained pursuant to aPTO.-Operations exempt from therule include:1) residentialnoncommercial coatingoperations, 2) coatingoperations where the metalinvolved does not constitutea substantive part of the totalsurface area, 3)coatingssupplied as aerosol products,4) operations subject toother prohibitory rules, and5) stripping (except whencleaning applicationequipment).-Solvents are exempt(except for recordkeeping)that have two percent or lesscontent of ROC and TAC.-The following are exemptfrom coating ROC contentlimits and the applicationmethods: 1) stencilcoatings, 2) safetyindicating coatings, 3)magnetic data storage diskcoatings, 4) solid-filmlubricants and 5) electricinsulating and thermalconducting coatings.-The solvent cleaningprovisions shall not apply to:from metal parts andproducts coating operations.-The solvent cleaningprovisions do not applywhere total usage ofnoncomplying substratesurface cleaners does notexceed 5 galls per rolling12-month period.STAFF REPORT–PARs 330, 337, 349, & 353Page J-10June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)1) semiconductors andmicroelectromechanicaldevices (thin filmdeposition, vacuumdeposition, dry etching,metal lift-off, and associatedmaintenance activities), 2)electronic components, 3)small encasements forelectronic components, 4)parts, subassemblies, orassemblies exposed tostrong oxidizers or reducers,5) transparencies,polycarbonate, or glasssubstrates, 6) solar cells,laser hardware, scientificinstruments, high-precisionoptics, telescopes,microscopes, and militaryfluid systems, and 7)cleaning/stripping ofpersonal protectiveequipment.- The rule does not applycoatings that contain lessthan 20 grams of reactiveorganic compound per liter(0.17 pounds of reactiveorganic compound pergallon) of coating, lesswaterand less exempt compounds,as applied.STAFF REPORT–PARs 330, 337, 349, & 353Page J-11June 21, 2012Santa Barbara County APCDSurface Coating of Metal Parts andProducts Performance StandardsRegulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4603(09/17/2009)San Luis Obispo CountyAPCD Rule 411(01/28/1998)Santa Barbara CountyAPCD Rule 330 (Proposed)Ventura County APCD Rule74.12 (04/08/2008)ApplicabilityThe provisions of this ruleshall apply to the surfacecoating of metal parts orproducts, large appliancesparts or products, metalfurniture, and plastic partsand products,automotive/transportationand business machine plasticparts and products, andpleasure crafts, and to theorganic solvent cleaning,and the storage and disposalof all solvents and wastesolvent materials associatedwith such coating.This Rule is applicable toany person who applies orspecifies the use of surfacecoatings to metalparts and productsThis rule is applicable to anyperson who manufacturesany metal partcoatingorproduct coating for usewithin the District, as wellas any person who uses,applies, or solicits the use orapplication of any metal partor product coating orassociated solvent within theDistrict.The provisions of this ruleapply to any person whoapplies or specified the useof surface coatings to metalparts or products.CommentsThe SJV Rule 4603 hasexemptions and limits forthe following that have beenomitted from this analysisfor brevity:-Dip coated steel joists,-Large appliance parts andproducts,-Metal furniture,-Plastic parts, and-Pleasure craft.The SBC Rule 330 only hasa fewcoatingcategories.Thespecialty coatingcategories, which arespecified inother airdistricts (e.g.,pretreatmentwash primer, hightemperature, high gloss,etc.),are subject to the SBCRule 330general coatinglimits.STAFF REPORT–PARs 330, 337, 349, & 353Page J-12June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)Ablative Coating2After 12/31/2012: 600600Adhesion Promoter850850 - to become 250 (effective 24months after the date of adoption)850AdhesivesCommercial Interior Adhesive2760Cyanoacrylate Adhesive21020Fuel Tank Adhesive2620Non-Structural250250250Rocket Motor Bonding Adhesive2890Rubber-Based Adhesive2850StructuralAutoclavable505050Nonautoclavable850850850Adhesive Bonding Primers780New Commercial Aircraft250250All Military Aircraft805805Remanufactured Commercial Aircraft Parts805805Sonic and Acoustic Applications805805Long Term250250Short Term250250Antichafe Coatings600600 - to become 420 (effective 24months after the date of adoption)600Barrier Topcoat420420420Bearing Coating2After 12/31/2012: 620620Caulking and Smoothing Compounds2After 12/31/2012: 850850Chemical Agent-Resistant Coating2After 12/31/2012: 550550Clear Topcoat520520Commercial Exterior Aerodynamic StructurePrimer2350Compatible Substrate Primer2350Conformal Coating750750Corrosion Prevention System Compound2710Cryogenic Flexible Primer2350Cryoprotective Coating26001The San Luis Obispo County APCD is omitted from this table asthey have no rule for this equipment/operation category.2This category is from the 1997 Control Techniques Guidelinefor Coating Operations at Aerospace Manufacturing and Rework Operations.STAFF REPORT–PARs 330, 337, 349, & 353Page J-13June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)Dry Lubricative MaterialsFastener Manufacturing120120250Nonfastener Manufacturing675675880Electric/Radiation Effect Coatings800800800Electrostatic Discharge and ElectromagneticInterference Coating2After 12/31/2012: 800800Elevated-Temperature Skydrol-ResistantCommercial Primer2350Epoxy Polyamide Topcoat2After 12/31/2012: 660660Exterior Primer3350Extreme Performance Interior Topcoat2420Fastener Sealants675After 12/31/2012: 600675 - to become 600 (effective 24months after the date of adoption)675Fire-Resistant (interior) Coating600Fire Resistant CoatingsCivilian (Interior)650650Flexible Primer2350Flight Test Coatings Used onMissiles or Single-Use Target Craft420420420All others600600600Fuel Tank Coating (Excluding Fuel TankAdhesive)2420Fuel Tank Coatings420General420Epoxy420Fuel Tank Adhesives620620High Temperature Coating850720850Impact Resistant Coating420420Insulation Covering2740Intermediate Release Coating2750Lacquer2After 12/31/2012: 830830Maskants - Chemical Milling250250Optical Anti-Reflective Coating700700Maskants:3The proposed amended Rule 337 lists this coating type in Table337-1, Reactive Organic Compound Content Limits for Coatings Other than SpecialtyCoatings. The six coating types in that table were modeled on categories found in 40 CFR, Part 63, Subpart GG, National Emission Standards for AerospaceManufacturing and Rework Facilities (Section 63.741et seq.). Coatings types from this NESHAP are shown inbold.STAFF REPORT–PARs 330, 337, 349, & 353Page J-14June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)Bonding Maskant21,230Critical Use and Line Sealer Maskant21,020Seal Coat Maskant21,230Metallized Epoxy Coating2After 12/31/2012: 740700Mold Release2After 12/31/2012: 780780Optical Anti-Reflective Coating2700Part Marking Coating2After 12/31/2012: 850850Pretreatment Coatings780780780Primer3350PrimersGeneral350Commercial Exterior Aerodynamic Structure350350Primers Not Resistant to Phosphate Esters350Primers Resistant to Phosphate EstersRain Erosion Resistant Coating800600420Rocket Motor Nozzle CoatingAfter 12/31/2012: 660660Scale Inhibitor880880880Sealant600Extrudable/Rollable/Brushable Sealant2600After 12/31/2012: 280280Sprayable Sealant2600Sealant Primer720Self-Priming Topcoat3420Silicone Insulating MaterialAfter 12/31/2012: 850850Solid Film LubricantsFastener Manufacturing250250Fastener Installation880880880Nonfastener Manufacturing880880880Space Vehicle CoatingsElectrostatic Discharge Protection800800800Other Space Vehicle Coatings100010001000Adhesives800800Specialized Function Coating2After 12/31/2012: 890890Temporary Protective Coatings250250250Thermal Control Coating2After 12/31/2012: 800800Topcoat3420Topcoats420420STAFF REPORT–PARs 330, 337, 349, & 353Page J-15June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)Type I Chemical Milling Maskant3250Type II Chemical Milling Maskant3160Unicoats (Self Priming Topcoats)420420Wet Fastener Installation Coating2After 12/31/2012: 675675Wing Coating750750420Wire CoatingsElectronic420420Anti-Wicking420420Pre-Bonding Etching420420Phosphate Ester Resistant Ink925925Spray Application Equipment TransferRequirementsElectrostatic, electrodeposition,flow coat,roll coat, dip coat,brush coat, orHVLP. Inlieu ofmeeting this requirement add-oncontrol equipment may be used.Electrostatic, electrodeposition, flowcoat, roll coat, dip coat, HVLP, handapplication, detailing or touch-upguns,or other approved methodthatcan demonstrate at least 65%transfer efficiency. Specificprovisions allow use of air-atomizedspray for certain adhesives.Electrostatic, flow coat, dipcoat, HVLP, hand application,or other approved methodthatcan demonstrate at least 65%transfer efficiency.Control Equipment Capture and ControlEfficiencyOverall capture and controlefficiency of85.5% or greater.Overall capture and controlefficiency of85.5% or greater.Compliance through the use of addon exhaust control equipment shallnot result in affected pollutantemissionsin excess of the affectedpollutant emissions that would resultfrom compliance withotherapplicable portions of the rule.Overall capture and controlefficiency of85%or greater.Solvent Use, Surface Preparation, and Clean UpThe solvent is to contain less than200 grams of ROC per liter ofmaterial, as applied, orhave anROC composite partial pressureless than or equal to45 mm Hg ata temperature of 20oC.In lieu ofmeeting this requirement add-oncontrol equipment may be used.The following becomes effectiveone-year after adoption of theamended rule.: When performingsurface preparation for coatingapplication and cleanup (other thanspray application equipmentcleaning)the solventis to containless than 200 grams of ROC per literof material, as applied, orhave anROC composite partial pressure lessthan or equal to45 mm Hg at atemperature of 20oC.No person shall use a solventfor surface cleaning, clean-upor engine gas path cleaningexcluding stripping coatings orcleaning coating applicationequipment unless1)containsless than 200 grams of ROCper liter of material, asapplied, or2)ROC compositepartial pressure of the solventis less than or equal to 25 mmHg at a temperature of 20oC.STAFF REPORT–PARs 330, 337, 349, & 353Page J-16June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)Except for solvent cleaning of sprayapplication equipment, any personperforming solvent cleaning with asolvent containing more than 25grams per liter of material shall useone or more of the followingcleaning devices or methods:1)Wipe cleaning where solvent isdispensed to wipe cleaning materialsfrom containers that are kept closedto prevent evaporation, except whiledispensing solvent or replenishingthe solvent supply;2)Application ofsolvent from hand-held spraybottles, squirt bottles, or other closedcontainers with a capacity of oneliter or less; or3) Non-atomizedsolvent flow, dip, or flush cleaningmethod where pooling on surfacesbeing cleaned is prevented ordrained, and all solvent runoff iscollected in a manner that enablessolvent recovery or disposal. Thecollection system shall be keptclosed to prevent evaporation exceptwhile collecting solvent runoff oremptying the collection system.Evaporative Loss MinimizationAn operator shall store or disposeof fresh or spent solvents, wastesolvent cleaning materials such ascloth, paper, etc., coatings,adhesives, catalysts, and thinnersin closed, non-absorbent and nonleaking containers. Thecontainers shall remain closed atall times except when depositingor removing the contents of thecontainers or when the containerClosed containers for storage anddisposal ofROC-containingmaterials (including cloth,paper,sand, etc.). Containers for ROCcontain materialsmust be closedwhen not in use. Minimize ROCcontaining materialspills and cleanup spills immediately.Dispose ofwastes that contain ROCs by 1) areclamation service, 2) a facility thattreats, stores, ordisposes of suchClosed containers shall beused for disposal and storageof cloth, paper, or othersolvent-containing materialsused for surface preparation,coating, cleanup, or paintremoval.STAFF REPORT–PARs 330, 337, 349, & 353Page J-17June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)is empty.wastes, or 3) recycling. Containersused to store ROC-containingmaterials shall be marked or clearlylabeled indicating thename of thematerial they contain.Solvent Use, Cleaning of Application EquipmentAn operator shall not use VOCcontaining materials to cleanspray equipment used for theapplication of coatings,adhesives, or ink, unless anenclosed system or equipmentthat is proven to be equallyeffective at controlling emissionsis used for cleaning. If anenclosed system is used, it musttotally enclose spray guns, cups,nozzles, bowls, and other partsduring washing, rinsing anddraining procedures, and it mustbe used according to themanufacturer’s recommendationsand must be closed when not inuse.In lieu of meeting thisrequirement add-on controlequipment may be used.Use a solvent with an ROC contentof25 grams per liter. In lieu ofmeeting the reactive organiccompound-content limit, a personmay use an enclosed cleaningsystem, orequipment that is provento the satisfaction of the ControlOfficer to be equally effective as anenclosed cleaning system atcontrolling emissions.(Becomeseffective one-year after adoption ofthe amended rule.)Use of 1) an enclosed gunwasher or "lowemission spraygun cleaner" that has beenapproved in writing by theAPCO, whichis properly usedfor spray equipment cleaning,and2)The ROC compositepartial pressure of organicsolvent used is less than 45mm Hg at 20oC.StripperNo operator shall use or specifyfor use within the District acoating stripper unless it containsless than 300 grams of VOC perliter (2.5 lb/gal), as applied, orunless it has a VOC compositevapor pressure of 9.5 mm Hg(0.18 psia) or less at 68°F.Inlieu of meeting thisrequirementadd-on control equipment may beused.No person shall apply any stripperunless it contains less than 300grams of ROC per liter, as applied,and/or unless its ROC compositepartial pressure is9.5mm Hg or lessat 20oC.No person shall use a coatingstripper unless it contains lessthan 300 grams of ROC perliter, as applied, or unless itsROC composite partialpressure is 9.5 mm Hg or lessat 20oC.Prohibition of SolicitationNo person shall solicit, specify,or require an operator to use anycoating, solvent, sprayNo person shall specify the use ofany coating on any aerospacevehicle or component subject to theNo person shall solicit, specifyor require any other person touse in the District any coating,STAFF REPORT–PARs 330, 337, 349, & 353Page J-18June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)equipment, or VOC emissioncontrol system that does not meetthe limits or requirements of thisrule.provisions of this rule, which, asapplied, contains reactive organiccompounds in excess of the limitsshown in the tables. No person shallspecify the use of any stripper unlessit complies with the provisions ofthe rule.adhesive, solvent, sprayequipment, or controlequipment that does not meetthe limits or requirements ofthis rule.Coating Labeling or Seller InformationRequirements (Compliance Statement)Coatings manufacturers shall displayon product labels a statementrecommending thinning (does notapply if thinning with water). Therecommendation shall specify thatthe coating is to be employedwithout thinning or diluting undernormal environmental andapplication conditions unless anythinning recommended on the labelfor normal environmental andapplication conditions does notcause a coating to exceed itsapplicable standard for reactiveorganic compound content.Eachcontainer of any coating subject totherule shalldisplay the maximumreactive organic compound contentof the coating, as applied, and afterany thinning as recommended by themanufacturer.Coatings manufacturers shalldesignate on product labels ordata sheets, the ROC contentor the Volatile OrganicCompounds (VOC) content ofcoatings including coatingreducers and catalysts, assupplied. This designationshall includerecommendations regardingthinning, reducing, or mixingwith any other ROCcontaining materials, andexpress the coating ROC orVOC content on an as appliedbasis when used in accordancewith the manufacturer'srecommendations.Liquid Cleaning MaterialLabeling or SellerInformation Requirements (ComplianceStatement)The manufacturer of liquidcleaning materials used incoatingoperations shalldesignate on product labels ordata sheets the ROC contentand ROC Composite PartialPressure of cleaning materialsas supplied. This designationshall includerecommendations regardingmixing with any other ROCSTAFF REPORT–PARs 330, 337, 349, & 353Page J-19June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)containing materials, andexpress the cleaning materialROC content when used inaccordance with themanufacturer'srecommendations.RecordkeepingMaintain records of ROCcontents, mix ratios,daily usagerecords ofcoatings, adhesivesstrippers,and solvents and itemscoated. Also, for solvents,maintain a record of the vaporpressure. Okay to maintainmonthlyrecords of materialuse ifonly using complying materials.Keep recordwhen using add-onemission control equipment.-Maintain a current file of all ROCcontaining materials that providesall information necessary to evaluatecompliance, including: 1) materialname and manufacturer ID, 2)application method, 3)manufacturer’s specific useinstructions (e.g., specific use forwhich the material is intended), typeoperation(e.g., coating, stripping, orsolvent cleaning), and for coatingsoperations, the coating type fromTables 337-1 or 337-2 and the typeequipment coated, 4) specificmixing volumes of each componentsfor each batch, 5) correspondingROC content limit and as appliedROC content of materials used, and6) current manufacturer'sspecification sheets, material safetydata sheets (MSDS), product datasheets,orair quality data sheets,which lists the ROC content.availableCompliance with thisprovisionmay be done byensuringthe manufacturer’s specifications arelisted on the product container.-Maintain records for each ROCcontaining material purchased foruse. The records shall include thefollowing: 1) material name andmanufacturerID, and 2) materialtype (e.g., coating type from TableMaintain records of ROCcontents, mix ratios, dailyusage records ofcoatings,adhesives strippers,andsolvents. Also, for solvents,maintain records of the ROCcomposite partial pressure.Okay to maintain monthlyrecordsof material useif onlyusing complying materials.Keep recordwhen using addon emission controlequipment.STAFF REPORT–PARs 330, 337, 349, & 353Page J-20June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)337-1 or Table 337-2, cleanupsolvent, stripper, etc.).- Maintain records of the disposalmethod each time waste solvent,waste solvent residue, or other wastematerial that contains ROCs isremoved for disposal.-Keepmonthly records of: 1)thevolume of the ROC-containingmaterialsused, 2) ROC content ofthe materials, and 3) resulting ROCemissions.-If claiming the §B.1 exemption,maintain: 1)daily volumes ofnoncomplyingcoatingsused by separateformulation,and2) annual runningtotals ofnon-complying coatingvolumes used for each separateformulation and all formulations.-When usingadd-on emissioncontrol equipment, maintain dailyrecords of key system operating andmaintenance data.-Any records requiredto bemaintained pursuant to the rule shallbe kept on site for at least 2 yearsunless a longer retention period isotherwise required by state orfederal regulation(s). Such recordsshall be readily available forinspection and review by theDistrict.Submittal of an Annual ReportSubmittal of an annual report isrequired if a person: 1) holds apermit for equipment subject to therule, or 2) a person is subject to theruleand applies non-complyingcoatings. The report is to include:1) monthly records required bySTAFF REPORT–PARs 330, 337, 349, & 353Page J-21June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)§H.4, 2) annual totals, 3) if claimingthe §B.1 exemption, the annualtotals ofnon-complying coatings per§H.7.b, and 4) if permitted, thename and address of thecompany oragency, and PTO number.ApplicabilityThis rule shall apply to themanufacturing, assembling,coating, masking, bonding, paintstripping, surface cleaning,service, and maintenance ofaerospace components, thecleanup of equipment, and thestorage and disposal of solventsand waste solvent materialsassociated with these operations.-This rule is applicable to anyperson who manufactures anyaerospace vehiclecoating orcomponent coating for use withinthe District, as well as any personwhouses, applies, or solicits the useor application of any aerospacevehicle or component coating orassociated solvent within theDistrict. Rule 337 does not apply toelectronic components.This rule is applicable to themanufacturing, assembling,coating, masking, bonding,paint stripping, and surfacecleaning of aerospacecomponents and the cleanupof equipment associated withthese operations. Where Rule74.12, Surface Coating ofMetal Parts and Products,applies to the coating orcleaning of metal parts,including but not limited totooling operations, this ruleshall not apply.Exemptions-Jet engine or rocket engineflushing operations using anysolvent other thantrichloroethylene are exemptfrom this rule.- Except for the recordkeepingprovisionsof Sections 6.1.1 and6.1.4, the requirements of Section5.0 shall not apply to aerospaceassembly and component coatingoperations using not more thanfour (4) gallons of productscontaining VOCs per day.Solvent-containing materials usedin operationssubject to Rule4662 (Organic SolventDegreasing Operations), shall notbe included in this determination.-Any non-complying coatings withseparate formulation used involumes of less than 20 gallons ofeachof each non-complyingformulationper stationary source inany calendar year is exempt fromthe ROC limit. To qualify for thisexemption, the total volume of noncomplying coatings at the stationarysourceshall not exceed 200gallonsannually. Coatings used foroperations that are exempt perSections B.2,B.3, B.6, B.8,B.11,B.12, and B.13shall not be includedin calculating the volume of coatingsused under this exemption.-The application method andrecordkeeping requirements do not-Except for the prohibition ofsolicitation provisions, Therule does notapply to anystationary source that emits <200 lbs in every rolling periodof 12 consecutive monthsfrom assembly and componentmanufacturing operations.Emissions from cold cleaners,vapor degreasers, and aerosolproducts, shall not be includedin thisdetermination.-Coating limits do not applyto: any coating withseparateformulationsused in volumesof less than 20 gallons in anycalendar yearor any adhesivewith separate formulationsSTAFF REPORT–PARs 330, 337, 349, & 353Page J-22June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)Except for the provisions ofSection 6.0, Section 5.0 shall notapply to laboratories which applycoatings, solvents, and adhesivesto test specimens for purpose ofresearch, development, qualitycontrol, and testing forproduction-related operations.Any person claiming thisexemption shall provideoperational records, data andcalculations, as determined by theAPCO to be necessary, tosubstantiatethis claim.-Except for the provisions ofSection 6.0, Section 5.0 shall notapply to laboratories which applycoatings, solvents, and adhesivesto test specimens for purpose ofresearch, development, qualitycontrol, and testing forproduction-related operations.Any person claiming thisexemption shall provideoperational records, data andcalculations, as determined by theAPCO to be necessary, tosubstantiate this claim.-The coating and adhesive limitsdo not apply to 1) Coatings oraerosols with separateformulations that are used involumes of less than one (1)gallon on any day or 20 gallonsin any calendar year at anaerospace assembly andcomponent coating stationarysource, or 2) Adhesives withseparate formulations that areapply to touch-up and repair,provided Section D.1 limits are metand records are maintained pursuantto aPTO.-The provisions ofthe ruledo notapply tocoatings supplied as aerosolproducts.-Any coating and associated solventcleaning subject to the requirementsof this rule shall be exempt from therequirements of Rule 317, OrganicSolvents, and Rule 322, MetalSurface Coating Thinner andReducer.-Solvents are exempt (except forrecordkeeping) that have twopercent or less content of ROC andTAC.-The rule does not apply coatingsthat contain less than 20 grams ofreactive organic compound per liter(0.17 pounds of reactive organiccompound per gallon) of coating,less water and less exemptcompounds, as applied.- Stripper and solvent requirementsdo not apply when performing spacevehicle manufacturing and rework.-The rule does not apply to chemicalmilling and electrodeposition(except for electrodeposition ofcoatings).-The solvent cleaning provisionsshall not apply to: 1) smallencasements for electroniccomponents, 2) parts,subassemblies, or assembliesexposed to strong oxidizers orreducers, 3) transparencies,used in volumes of less than10 gallons in any calendaryear ata stationary coatingsource, providedthat the totalvolume of noncomplyingcoatings (excludingnoncomplying adhesives) usedat a stationary source does notexceed 200 gallons annually.In addition, a person claimingthe 20 gallons of coating peryear exemption shall notifythe APCO in writing thatsubstitute complying coatingsare not available.-Surface cleaningrequirements do not apply tothe cleaning of aerospaceassembly and subassemblysurfaces that are exposed tostrong oxidizers or reducerssuch as nitrogen tetroxiode,liquid oxygen or hydrazine.-The coating transferefficiency requirements do notapply tothe application ofcoatings thatcontain less than20 grams of ROC per liter ofcoating less water and lessexempt organic compounds.-The ruledoesnot apply toaerosol coating products.STAFF REPORT–PARs 330, 337, 349, & 353Page J-23June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)used in volumes of less than onehalf (0.5) gallon on any day orten (10) gallons in any calendaryear at an aerospace assemblyand component coating stationarysource.--The coating transfer efficiencyrequirements do not apply to theapplication of coatings that 1)containless than 20 grams ofROC per liter of coating lesswater and less exempt organiccompounds, or 2) Are dispensedfrom hand-held aerosol cans.polycarbonate, or glass substrates,and 4) solar cells, laser hardware,scientific instruments, highprecision optics, telescopes,microscopes, and military fluidsystems.-The application methodrequirements do not apply to 1) anysituation that normally requires theuse of an airbrush or an extension onthe spray gun to properly reachlimited access spaces, or 2) the useof airbrush application methods forstenciling, lettering, and otheridentification markings.-Section D.1, Table 337-1 chemicalmillingmaskant limits shall notapplyto: 1) touch-up of scratchedsurfaces or damaged maskant, and2) touch-up of trimmed edges.-Section D.1 shall not apply toelectric- and radiation-effectcoatings that have been designatedas “classified” by the United StatesDepartment of Defense.-The rule shall not apply to coatings(including adhesive products andsealant products) subject to the AirResources Board consumerproductsregulation found in Title 17 of theCalifornia Code of Regulations,section 94507 et seq.- Stripping/solvent requirements todo not apply to the cleaning ofpersonal protective equipment.-wipe cleaning of breathing oxygensystems, surfaces prior to adhesivebonding, aircraft and ground supportequipment that are exposed to fluid,STAFF REPORT–PARs 330, 337, 349, & 353Page J-24June 21, 2012Santa Barbara County APCDSurface Coating of Aerospace Vehicles and Components Performance Standards1Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4605 (06/16/2011)Santa Barbara County APCD Rule337 (Proposed)Ventura County APCD Rule74.13 (11/11/2003)fuel cells/tanks, confined spaces,associated with upholstery, curtains,and honeycomb cores.CommentsStaff included definitions andcoating categories from the 1997Control Techniques Guidelines andthe federal NESHAP for aerospacemanufacturing and rework facilities.Polyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)General Polyester Resin Material or GeneralPurpose Resin635%35%Marble or Cultured Resins - VC TermMarble Resins - SJV TermAfter 12/31/2012: 10% or32%, as supplied, with no fillers2-years after rule adoption: 10%or32%, as supplied, with nofillers10% or 32% as supplied, no fillerSolid Surface ResinsAfter 12/31/2012: 17%2-years after rule adoption: 17%17% by weight monomer content.Tub/Shower ResinsAfter 12/31/2012: 24% or35%, as supplied, with no fillers2-years after rule adoption: 24%or35%, as supplied, with nofillers24% or 31% as supplied, no fillerLamination ResinsAfter 12/31/2012: 31% or35%, as supplied, with no fillers2-years after rule adoption: 31%or35%, as supplied, with nofillers31% or 35% as supplied, no fillerTooling Resin6Atomized (spray) 30%After 12/31/2012: 30%2-years after rule adoption: 30%Non-atomized 39%After 12/31/2012: 39%2-years after rule adoption: 35%Specialty Resin650% and use of low VOCpolyester resins.50%Fire Retardant ResinAfter 12/31/2012: 38%2-years after rule adoption: 38%38%High Strength MaterialsAfter 12/31/2012: 40%2-years after rule adoption: 40%40%4The San Luis Obispo County APCD is omitted from this table asthey have no rule for this equipment/operation category.5The San Joaquin Valley Unified APCD Rule 4684 has special provisions forfiberglass boat manufacturing. Essentially those provisions require the use of aclosed molding process and the monomer content limits shown inthe table, coupled with solvent cleaning provisions, and solventstorage and disposalrequirements. In lieu of meeting those provisions, there are various compliance options. For the purposes of brevity, additional details of the SJV Rule 4684provisions onfiberglass boat manufacturingare omitted from this analysis.6The monomer content of the material shall not be more than the percentages specified, by weight, as applied.STAFF REPORT–PARs 330, 337, 349, & 353Page J-25June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)Corrosion Resistant ResinAfter 12/31/2012: 48%2-years after rule adoption: 48%48%All Other Resin6After 12/31/2012: 35%2-years after rule adoption: 35%35%Corrosion-Resistant Materials or Resins6See Specialty Resins.See Specialty Resins.Fire Retardant Materials or ResinSee Specialty Resins.See Specialty Resins.Tooling Gel CoatAfter 12/31/2012: 40%2-years after rule adoption: 40%Gel CoatSee Clear Gel Coat andPigmented Gel Coat.See Clear Gel Coat andPigmented Gel Coat.See Clear Gel Coat andPigmented Gel Coat.Clear Gel Coat650%50%Marble ResinsAfter 12/31/2012: 40%2-years after rule adoption: 40%40%All Other ResinsAfter 12/31/2012: 44%2-years after rule adoption: 44%44%Pigmented Gel Coat645% and use of low VOCpigmented gel coats.45%White and Off WhiteAfter 12/31/2012: 40%2-years after rule adoption: 30%30%Non-WhiteAfter 12/31/2012: 37%2-years after rule adoption: 37%37%PrimerAfter 12/31/2012: 28%2-years after rule adoption: 28%28%Specialty Gel CoatAfter 12/31/2012: 48%Resin Containing Vapor SuppressantWeight loss from ROC emissions<60 g/sq. m.Weight loss from ROC emissions<60 g/sq. m.Weight loss from ROC emissions<60 g/sq. m.Closed Mold SystemYes, no limit.Yes, no limit.Yes, no limit.Thinning or Diluting ProhibitionComplying formulations shall notbe thinned or diluted with anyROC or changed in any mannerthat may increase ROC emissionsafter testing, but prior to orduring application.Spray Application Equipment TransferRequirementsSpray application of polyesterresin shall only be performedusing airless, air assisted airless,high-volume, low-pressure(HVLP) spray equipment, orelectrostatic spray equipment.High-Volume, Low-Pressure(HVLP) spray equipment shall beoperated in accordance with themanufacturer’srecommendations.Spraying operation shall use onlyairless, air-assisted airless, highvolume low pressure sprayequipment, or electrostatic sprayequipment as approved by theControl Officer and operated inaccordance with themanufacturer's recommendations.Airless, air-assisted airless,electrostatic, or high volume-lowpressure spray equipment shall beused in any spray application,except for touch-up or repairusing a hand-held, air-atomizedspray gun utilizing an attachedresin container of no more thanone quart capacity.Control Equipment Capture and ControlEfficiency90% overall capture and controlefficiency or greater.85%, which becomes 90% twoyears after adoption, overall90% overall capture and controlefficiency or greater.STAFF REPORT–PARs 330, 337, 349, & 353Page J-26June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)capture and control efficiency orgreater. Compliance through theuse of an emission control systemshall not result in affectedpollutant emissions in excess ofthe affected pollutant emissionsthat would result fromcompliance with the otherapplicable rule provisions.Solvent Use, Surface Preparation, and Clean UpAll cleaning solvents (includingproduct cleaning duringmanufacturing, surfacepreparation, and repair andmaintenance cleaning) shall havean ROC content of 25 g/l or less.The following becomes effectiveone-year after adoption of theamended rule:All cleaningsolvents (including productcleaning during manufacturing,surface preparation, and repairand maintenance cleaning) shallhave an ROC content of 25 g/l orless.Cleaning material used on lines,rollers, brushes, spray equipmentand personnel, shall be either aClean Air Solvent or shall notexceed 25 grams ROC per liter ofmaterial as applied.Evaporative Loss MinimizationAn owner or operator shall storeor dispose of all uncuredpolyester resin materials, fresh orspent solvents, waste solventcleaning materials such as cloth,paper, etc., coatings, adhesives,catalysts, and thinners in selfclosing, non-absorbent and nonleaking containers. Thecontainers shall remain closed atall times except when depositingor removing the contents of thecontainers or when the containeris empty.Closed containers for storage anddisposal of ROC-containingmaterials (including cloth, paper,sand, etc.). Containers for ROCcontain materials must be closedwhen not in use. Minimize ROCcontaining materials spills andclean-up spills immediately.Dispose of wastes that containROCs by 1) a reclamationservice, 2) a facility that treats,stores, or disposes of suchwastes, or 3) recycling.All materials containing reactiveorganic compounds, used orunused, including but not limitedto semi-solid or liquid polyesterresin materials and solid or liquidcleaning materials, shall be storedin closed containers and shall notleak.Solvent Use, Cleaning of Application EquipmentSolvents shall have an ROCcontent of 25 g/l or less.Solvents shall have an ROCcontent of 25 g/l or less.(Becomes effective one-year afteradoption of the amended rule.)Cleaning material used on lines,rollers, brushes, spray equipmentand personnel, shall be either aClean Air Solvent or shall notexceed 25 grams ROC perliter ofmaterial as applied.Recordkeeping-An operator subject to this ruleMaintain records of 1) the type ofRecords shall contain: 1)STAFF REPORT–PARs 330, 337, 349, & 353Page J-27June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)shall maintain the followingrecords: 1) daily records of thetype and quantity of all resins, gelcoats, fillers, catalysts, andcleaning materials (includingcleaning solvents) used in eachoperation, 2) records of the VOCcontent, in weight percent, of allpolyester resin and gel coat, fillermaterials, including the weightpercent of non-monomer VOCcontent of the resin and gel coat,used or stored at the stationarysource, 3) records of the VOCcontent of all cleaning materialsused and stored at the stationarysource, and 4) records showingthe weight loss per square meterduring resin polymerization foreach vapor-suppressed resin.-An operator claiming the 20gallons permonth exemptionshall maintain records ofpolyester materials usage tosupport the claim of exemption.resin, catalyst, and cleaningmaterials used, 2)if applyingpolyester resin materials inspraying operations, the sprayapplication method used (e.g.,airless, air-assisted airless, etc.),3) for approved vapor suppressedresins, the weight loss in g/sq. m,monomer percent, and gel time,4)if mixing solvents,specificsolvent mixing volumes of eachcomponent for each batch,5) theactualas appliedROC compoundcontent of solventand, when notusing a closed mold system, thecorresponding monomer contentlimits from Sections D.1.a, b, orc, and the actual as appliedmonomer contents, or if using avapor suppressant the actualpolyester or vinyl ester resinweight loss rate of the materialused, and6) currentpolyesterresin material and solventmanufacturer's specificationsheets, material safety data sheets(MSDS), product data sheets, orair quality data sheets, whichliststhe ROC content. Compliancewith this provision may be doneby ensuring the manufacturer’sspecifications are listed on theproduct container.-Maintain records for each ROCcontaining material purchased foruse. The records shall includethe following: 1)material nameand manufacturer ID, and 2)material type.monthly reports (initialed byoperator) of the manufacturer andproduct number of each polyesterresin material and cleaningmaterial used, 2) the monomercontent in percent by weight ofeach polyester resin materialused, both as applied and assupplied. For cleaning material,the ROC content in grams ofROC per liter of material asapplied.Documentation shall beavailable to support theserecords. If using add-on controlequipment, daily reports of thecontinuous control efficiencymonitoring information. Ifclaiming the 20 gallons permonth exemption, in lieu of 1, 2,and 3 above, maintain monthlyrecords of the amount ofpolyester resin material used.STAFF REPORT–PARs 330, 337, 349, & 353Page J-28June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)- Maintain records of the disposalmethod each time waste solvent,waste solvent residue, or otherwaste material that containsROCs is removed for disposal.-Keep monthly records ofvolumes used, polyester resinmaterial as-applied monomercontent and solvent ROC content,and resulting ROC emissions.-Maintain records when usingadd-on emission controlequipment.-If claiming the §B.1 exemption,maintain monthly records ofstyrene volumes used to supportthe exemption claim.-Any records required to bemaintained pursuant to the ruleshall be kept on site for at least 2years unless a longer retentionperiod is otherwise required bystate or federal regulation(s).Such records shall bereadilyavailable for inspection andreview by the District.Submittal of an Annual ReportSubmittal of an annual report isrequired if a personholds apermit for equipment subject tothe rule. The report is to include:1) monthly records required by§F.4, 2) annual totals, 3) ifclaiming the §B.1 exemption, theannual totals ofstyrene used per§F.6, and 4) the name andaddress of thecompany oragencyandthe PTO the polyesterresin operation is subject to.ApplicabilityApplicability The provisions ofThis rule shall apply to anyThis rule is applicable to theSTAFF REPORT–PARs 330, 337, 349, & 353Page J-29June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)this rule apply to commercial andindustrial polyester resinoperations, fiberglass boatmanufacturing operations, and tothe organic solvent cleaning, andthe storage and disposal of allsolvents and waste solventmaterials associated with suchoperations.person owning or operating anycommercial or industrialpolyester resin operation.manufacture of products from orthe use of polyester resinmaterial, including touch-up,repair and rework activities.Exemptions-Other than the recordkeepingrequirements, theprovisions ofthis rule shall not apply polyesterresin operation using less than 20gallons per month of polyesterresin material.-The solvent cleaning provisionsdo not apply to 1) cleaning ofsolar cells, laser hardware,scientific instruments, or highprecision optics, and 2) cleaningin laboratory tests and analyses,or bench scale or research anddevelopment projects.-Resins and gel coats used fortouch up, repair, or small jobs,may have a monomer contentlimit up to 10% more than theapplicable limit set forth in Table1.Such resins or gel coatsshallonly be applied by a hand-heldatomized spray gun whichhas acontainer for the resin or gel coatas part of the gun.Resins or gelsapplied by another method shallcomply with theapplicable limitin Table 1.Total material use forall small jobsat a facility shallnot exceed two (2) gallons a day.-Polyester resin material limits donot apply to the addition or use ofstyrene, provided the volume ofstyrene used is less than 50gallons per calendar year perstationary source.-Solvents are exempt (except forrecordkeeping) that have twopercent or less content of ROCand TAC.-This rule shall not apply topolyester resin operationsperformed with polyester resinmaterials that contain no reactiveorganic compounds.-The solvent cleaning provisionsshall not apply to: 1) semiconductors and microelectromechanical devices (thin filmdeposition, vacuum deposition,dry etching, metal lift-off, andassociated maintenanceactivities), 2) electroniccomponents, 3) smallencasements for electroniccomponents, 4) parts,subassemblies, or assembliesexposed to strong oxidizers orreducers, 5) transparencies,polycarbonate, or glassThe provisions of Section B ofthis rule shall not apply tostationary sources using not morethan 20 gallons per month ofpolyester resin material.STAFF REPORT–PARs 330, 337, 349, & 353Page J-30June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)substrates, 6) solar cells, laserhardware, scientific instruments,high-precision optics, telescopes,microscopes, and military fluidsystems, 7) cleaning/stripping ofcoating off of personal protectiveequipment, and 8) space vehicles.-Section H shall not apply topolyester resin operationsproduction or rework of thefollowing products, provided thesolvents used contain 200 gramsof reactive organic compound perliter of material or less or have acomposite partial pressure of a 45millimeter of mercury at 20degrees Celsius:1) satellites,satellite components, aerospacevehicles, aerospace vehiclecomponents, aerospace vehiclepayloads, or aerospace vehiclepayload components.-Solvent cleaningshall not applyto polyester resin operationsproduction or rework of productsused in any laboratory tests oranalyses, includingqualityassurance or quality controlapplications, bench scaleprojects, or short-term (less than2 years) research anddevelopment projects. Recordsare to be kept when claiming thisexemption.-Solvent cleaning shall not applyto cleaning/stripping of polyesterresin material off of personalprotective equipment.CommentsPer ARB suggestions, we are: 1)STAFF REPORT–PARs 330, 337, 349, & 353Page J-31June 21, 2012Santa Barbara County APCDPolyester Resin Operations Performance Standards4Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4684 (06/16/2011)5Santa Barbara County APCDRule 349 (Proposed)Ventura County APCD Rule74.14 (04/12/2005)lowering the polyester resinmaterialmonomer content limits,and 2) increasing the emissioncontrol equipment efficiency.The District isalsoamending therule’ssolventcleaning provisionsper the 2010 Clean Air Plancommitment.Adhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7ADHESIVES/SEALANT PRODUCTS -SPECIFIC APPLICATION LIMITSAdhesivesABS welding400 (325)400400Cellulosic plastic welding(100)Ceramic floor tile(65)65Ceramic tile installation130 (65)13065Computer diskette jacket manufacturing850Contact bond (contact adhesive)250 (80)25080Contact bond-specialty substrates250400250Cove base installation150 (50)15050CPVC welding490490490Drywall(50)50Elastomeric(750)Flexible vinyl(250)Floor covering installation(150)Indoor carpet or carpet pad(50)50Indoor floor covering installation (exceptceramic tile installation)150150Metal to urethane/rubber molding or casting850 (250, effective 12 months7The San Luis Obispo County APCD is omitted from this table asthey have no rule for this equipment/operation category.8Rule 4653 and Rule 74.20 group the materials in a manner that deviates from the model rule in the ARB Reasonably Available Control Technology and BestAvailable Control Technology guidance document for adhesives and sealants. Staff has attempted to show the SJV and VC limits for the categories thatcorrespond to that model rule. The SJV Rule4653 has stricter requirements that go into effect on January 1, 2012. The valuesshown in parentheses reflect thelimits that become effective in 2012.STAFF REPORT–PARs 330, 337, 349, & 353Page J-32June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7after the date of amended ruleadoption)Motor vehicle(250)Motor vehicle weatherstrip(750)Multipurpose construction (except cove baseinstallation)200 (70)200 (70, effective 12 monthsafter the date of amended ruleadoption)70Nonmembrane roof installation/repair300300300Other flooring150Other plastic cement welding450 (250)510 (250, effective 12 monthsafter the date of amended ruleadoption)500Outdoor floor covering installation (outdoorcarpet)(150)250150Nonmembrane roof installation/repair(300)300300Panel(50)50Perimeter bonded sheet vinyl flooringinstallation660660Plastic cement welding(400)PVC welding510510 (500, effective 12 monthsafter the date of amended ruleadoption)Rubber flooring(60)60Rubber vulcanization850Sheet-applied rubber installation850850Single-ply roof membrane installation/repair(250)250250Staple and nail manufacturing640Structural glazing100100100Structural wood member(140)140Styrene-acrylonitrile welding(100)100Subfloor(50)50Thin metal laminating(780)780Tire retread100100100Top and Trim Adhesive(540)540Traffic marking tape(150)150150VCT and asphalt tile(50)50Waterproof resorcinol glue170170Wood flooring(100)100STAFF REPORT–PARs 330, 337, 349, & 353Page J-33June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7SealantsArchitectural(250)250250Marine deck(760)760760Nonmembrane roof installation/repair(300)300300Roadway(250)250250Single-ply roof membrane(450)450450Other(420)420420Adhesive Primers250Automotive glass(700)700700Plastic cement welding650650Rubber vulcanization850Single-ply roof membrane250Traffic marking tape(150)150Other250250Other plastic welding500Sealant PrimersArchitectural–non porous(250)250250Architectural–porous(775)775775Marine deck(760)760460Modified bituminous(500)Other(750)750760STAFF REPORT–PARs 330, 337, 349, & 353Page J-34June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7NONSPECIFIC APPLICATIONS OFADHESIVES/SEALANT PRODUCTS ONTOSUBSTRATESFlexible vinyl250250Fiberglass(80)200 (80, effective 12 monthsafter the date of amended ruleadoption)80Metal to metal303030Plastic foam120 (50)50Porous material120 (50)120 (50, effective 12 monthsafter the date of amended ruleadoption)Porous material (except wood and plastic foam)50Pre-formed rubber products250Reinforced plastic composite250 (200)Rubber250Wood3030Other substrates250250Thinning or Diluting ProhibitionSpray Application Equipment TransferRequirementsElectrostatic, electrodeposition,flow coat, roll coat, dip coat,HVLP, hand application,detailing or touch-up guns, orother approved method that candemonstrate a transfer efficiencyequivalent to or greater than theHVLP efficiency. Specificprovisions allow use of airatomized spray for certainadhesives.Electrostatic, electrodeposition,flow coat, roll coat, dip coat,HVLP, hand application,detailing or touch-up guns,orother approved methodthat candemonstrate at least 65% transferefficiency. Specific provisionsallow use of air-atomized sprayfor certain adhesives.Solvent Use, Surface Preparation, and Clean UpProduct Cleaning DuringManufacturing Process andSurface Preparation:1. General: 25 g/l of ROC2. Surface preparation beforerubber vulcanization process:850 g/lRepair and MaintenanceCleaning: 25 g/l of ROCEffective [one year from the dateof amended rule adoption],except as provided in Section I(add-on control equipment), noperson shall use any solventcontaining more than 25 g/l ROCfor the removal of uncuredadhesive products or uncuredsealant products from surfaces.Surface Preparation:-Single Ply Roof MembraneInstallation: ROC CompositePartial Pressure≤45 mm of HgPartial Pressure at 20oC.-Inkjet Printer Head Assembly:ROC Content≤200 g/l ofmaterial.-All Others: ROC Content≤70STAFF REPORT–PARs 330, 337, 349, & 353Page J-35June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7g/l of material.Cleanup (other than applicationequipment cleaning):ROC Composite Partial Pressure≤45 mm of Hg Partial Pressureat 20oC.Evaporative Loss MinimizationAn operator shall store or disposeof adhesive products, sealantproducts, catalysts, thinners, freshor spent solvents, and wastesolvent materials such as cloth,paper, etc., in closed, nonabsorbent and non-leakingcontainers. The containers shallremain closed at all times exceptwhen depositing or removing thecontents of the containers orwhen the container is empty. Thecontainers used for disposal ofadhesive materials, solvents, orany unused VOC containingmaterials shall be self-closing.Minimize VOC-containingmaterials spills and clean-upspills immediately.Closed containers for storage anddisposal of ROC-containingmaterials (including cloth, paper,sand, etc.). Containers for ROCcontain materials must be closedwhen not in use. MinimizeROC-containing material spillsand clean-up spills immediately.Dispose of wastes that containROCs by 1) a reclamationservice, 2) a facility that treats,stores, or disposes of suchwastes, or 3) recycling.Containers used to store ROCcontaining materials shall bemarked or clearly labeledindicating the name of thematerial they contain.All ROC-containing materialsshall be stored in nonabsorbent,nonleaking containers, whichshall be closed except whenadding or removing materials.Solvent Use, Cleaning of Application Equipment25 g/l of VOC. If cleaningapplication equipment used toapply rubber vulcanizationprimers or adhesives without addon controls, a solvent with aVOC content > 25 g/l and≤850g/l may be used if certaincleaning methods andprohibitions are followed. Whenusing a VOC-containing materialto clean spray equipment, anenclosed cleaning system shall beused.Use a solvent with an ROCcontent of 25 grams perliter. Inlieu of meeting the reactiveorganic compound-content limit,a person may use an enclosedcleaning system, or equipmentthat is proven to the satisfactionof the Control Officer to beequally effective as an enclosedcleaning system at controllingemissions. (Becomes effectiveone-year after adoption of theamended rule.)Use of 1) an enclosed gun washeror "low emission spray guncleaner" that has been approvedin writing by the APCO, which isproperly used for sprayequipment cleaning, and TheROC composite partial pressureof organic solvent used is lessthan 45 mm Hg at 20oC, or 2) Asolvent≤70 g/l ROC shall beused for cleaning, flushing orsoaking of filters, flushing lines,pipes, pumps, and other parts ofthe application equipment. PartsSTAFF REPORT–PARs 330, 337, 349, & 353Page J-36June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7containing dried adhesive may besoaked in an organic solvent aslong as the ROC compositepartial pressure of the solvent is9.5 mm Hg or less at 20oC.StripperThe following becomes effectiveone-year after adoption of theamended rule: No personshallapply any stripper unless itcontains less than300 grams ofROC per liter, as applied, and/orunless its ROC composite partialpressure is9.5mm Hg or less at20oC.No person shall use an adhesivestripper unless its ROCcomposite partial pressure is 9.5mm Hg or less at 20oC.Aerosol Adhesives Reactive Organic CompoundLimitExcept as provided in Section I(use of add-on controlequipment), no person shall useany aerosol adhesive unless thereactive organic compoundcontentcomplies with theAirResources Board consumerproducts regulation found in Title17 of the California Code ofRegulations, section 94507 etseq.Control Equipment Capture and ControlEfficiencyOverall efficiency of 85% orgreater. Use of the ROCemission control systemshall notresult in emissions in excess ofthose that would have beenemitted had the operatorcomplied with other applicablerule provisions.Overall efficiency of 85.5% orgreater. Use of the ROCemission control system shall notresult in emissions inexcess ofthose that would have beenemitted had the operatorcomplied with other applicablerule provisions.Overall efficiency of 85% orgreater.Prohibition of SalesExcept as provided in Section 4.3(products shipped out of airdistrict or sold to facilities withadd-on controls), no person shallsupply, sell, or offer for sale anyadhesive product or sealantExcept as provided in SectionB.10, no person shall supply, sell,or offer for sale any: 1)adhesiveproduct or sealant product that, atthe time of sale,is defined undera product category in Table 353-No person shall supply, sell, oroffer for sale any adhesive,sealant or primer which, at thetime of sale, is defined under aproduct category in SubsectionB.2, and exceeds the ROC limitsSTAFF REPORT–PARs 330, 337, 349, & 353Page J-37June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7product that does not meet thelimits as specified in Section 5.1(material VOC limits) or 5.4(add-on control equipmentlimits).1 and exceeds the reactiveorganic compound limit listed inTable 353-1, and 2) aerosoladhesive unless, at the time ofsale, the provisions of the AirResources Board consumerproduct regulation, found in Title17 of the California Code ofRegulations, section 94507 etseq., are met.listed in Subsection B.2 after thespecified effective dates. Thisprovision only applies to productsthat are supplied toor sold topersons within the District. Theprohibition of sales does notapply when thesale isto a userthat has add-on controlequipment.Prohibition SpecificationNo person shall solicit, requirefor use, or specify the applicationof any adhesive products orsealant products, if such use orapplication results in a violationof the provisions of this Rule.This prohibition shall apply to allwritten or oral contracts.No person shall solicit, requirefor use, or specify the applicationof any adhesive products, sealantproducts, or associated solvent ifsuch use or application results ina violation of the provisions ofthis rule. This prohibition shallapply to all written or oralcontracts.No person shall solicit, requirefor use, or specify the applicationof any adhesive, primer orsealant, if such use or applicationresults in a violation of theprovisions of this Rule. Thisprohibition shall apply to allwritten or oral contracts.Manufacturer Compliance Statement or LabelingRequirementsManufacturers of adhesiveproducts, sealant products, andsolvents shall label the materials:1) VOC Content: Each containerof adhesive product and sealantproduct subject to this rule shalldisplay the maximum VOCcontent of the adhesive productor sealant product as applied.VOC content shall be displayedas grams of VOC per liter ofadhesive product or sealantproduct, excluding water andexempt compounds, or grams ofVOC per liter of material for lowsolids adhesive products. Eachcontainer of solvent subject tothis rule shall display themaximum VOC content (ingrams of VOC per liter ofThe manufacturer of anyadhesive products or sealantproducts subject to this rule shalldisplay the maximum volatileorganic compound content assupplied, determined by theappropriate test method, on labelsor containers.This designationshall display recommendationsregarding thinning, reducing, ormixing with any other volatileorganic compound containingmaterial. This information shallinclude the maximum volatileorganic compound content on anas-applied basis whenused inaccordance with themanufacturer's recommendations.The manufacturer of anyadhesive, sealant, sealant primeror adhesive primer subject to thisrule and manufactured after July19,1997, shall include adesignation of the maximumROC or VOC content assupplied, including adhesivecomponents, expressed in gramsper liter or pounds per gallonexcluding water and exemptorganic compounds from theappropriate test method, oncontainers and data sheets. Thisdesignation shall includerecommendations regardingthinning, reducing, or mixingwith any other ROC or VOCcontaining materials. Thisstatement shall include theSTAFF REPORT–PARs 330, 337, 349, & 353Page J-38June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7material) as supplied; 2) eachcontainer of adhesive product orsealant product subject to thisrule shall display a statement ofthe manufacturer'srecommendations regardingthinning, reducing, or mixing ofthe adhesive product with anyother VOC containing material.Mixing recommendations shallspecify a ratio which results in acompliant, as applied, adhesiveproduct, or sealant product; and3) indicate on the solventcontainer, or on a separateproduct data sheet or materialsafety data sheet, the name of thesolvent, manufacturer's name, theVOC content, and density of thesolvent, as supplied. The VOCcontent shall be expressed inunitsof grams per liter orlb/gallon.maximum ROC or VOC on anas-applied basis when used inaccordance with themanufacturer's recommendations.Liquid Cleaning Material Compliance Statementor Labeling RequirementsSee above.The manufacturer of liquidcleaning materials subject to thisrule shall designate on productcontainers and data sheets theROC content and ROCComposite Partial Pressure ofcleaning materials as supplied.This designation shall includerecommendations regardingmixing with any other ROCcontaining materials, and expressthe cleaning material ROCcontent when used in accordancewith the manufacturer'srecommendations. All letters andnumbers used to designate ROCSTAFF REPORT–PARs 330, 337, 349, & 353Page J-39June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7or VOC content on product labelsshall be visible and legible.Sell-Through of Adhesives and Sealants1) An adhesive product or sealantproduct manufactured prior to theeffective date specified for thatproduct in Section 5.1 (VOClimits),may be sold, supplied, oroffered for sale for up to 12months after the specifiedeffective date.2) An adhesive product or sealantproduct manufactured prior to theeffective date specified for thatproduct in Section 5.1 (VOClimits) may be applied up to 24months after the specifiedeffective date.1) and 2)aboveonly apply tothose adhesive products orsealant products which arelabeled to display the date or datecode indicating when the productwas manufactured and thatcomplied with the standardsineffect at the time the product wasmanufactured.See exemptions.RecordkeepingAn operator subject to the rule’sadhesive/sealant product VOClimits shall maintain thefollowing records: 1) records ofthe VOC content, in grams VOCper liter, of all adhesive materialsused and stored at the stationarysource; 2) records of the VOCcontent of all solvents used andstored at the stationary source;and 3) effective on and afterJanuary 1, 2012, records of the-Maintain a current file of allROC-containing materials thatprovides all informationnecessary to evaluate compliance,including: 1) material name andmanufacturer ID; 2) applicationmethod;3) material type,manufacturer’sspecific useinstructions (e.g., specific use forwhich the material is intended),type operation (e.g., coating,stripping, or solvent cleaning),As required by a District permitcondition, maintain a file/recordsof ROC contents, mix ratios, andmonthly usage rates of coatings,adhesives strippers, and solventsand items coated. Also, ifcomplying with the ROCcomposite partial pressure,maintain a record of the ROCcomposite partial pressure. Keepdaily recordsof non-compliantmaterial use. Maintain recordsSTAFF REPORT–PARs 330, 337, 349, & 353Page J-40June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7VOC content, in grams VOC perliter, of all sealant materials usedand stored at a stationary source.-An operator that claims anexemption from the prohibitionof sales (i.e., materials shippedout of the air district or sold tocustomers with add-on controls)shall: 1)Keep a copy of themanufacturer’s product data sheetor material safety data sheet ofthe solvents used for organicsolvent cleaning activities; andName, address, and telephonenumber of the persons to whomthe adhesive products or sealantproducts are sold.-Solvent cleaning records shallinclude: 1) manufacturer’sproduct data sheet or materialsafety data sheet of the solventsused for organic solvent cleaningactivities; 2) a current list ofsolvents that are being used fororganic solvent cleaningactivities. The list shall includethe following information: a) thename of the solvent and itsmanufacturer’s name; b) theVOC content of the solventexpressed in grams per liter orlb/gallon; c)when the solvent is amixture of different materials thatare blended by the operator,themix ratio of the batch shall berecorded and the VOC content ofthe batch shall be calculated andrecorded in order to determinecompliance with the specifiedand for coating operations, theproduct type, type of substratecoated, and type of application(i.e., adhesive and sealant producttype from Table 353-1 or Table353-2); 4) specific mixingvolumes of each components foreach batch, 5) correspondingROC content limit and as appliedROC content of materials used;and 6) current manufacturer'sspecification sheets, materialsafety data sheets (MSDS),product data sheets,or air qualitydata sheets, whichlists the ROCcontent.Compliancewith thisprovisionmay be done byensuring the manufacturer’sspecifications are listed on theproduct container.-Maintain records for each ROCcontaining material purchased foruse. The records shall includethe following: 1) material nameand manufacturer ID, and 2)material type(e.g., adhesiveproduct and sealant product typefrom Tables 353-1 and 353-2,cleanup solvent, stripper, etc.).- Maintain records of the disposalmethod each time waste solvent,waste solvent residue, or otherwaste material that containsROCs is removed for disposal.-Keep monthly records of: 1) thevolume of the ROC-containingmaterials used, 2) ROC contentof the materials, and 3) resultingROC emissions.when using add-on emissioncontrol equipment.STAFF REPORT–PARs 330, 337, 349, & 353Page J-41June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7limits of VOC content, asapplied; d) the type of cleaningactivity for each solvent that isbeing used in accordance with theapplicable cleaning categoryspecified in Table 6 of this rule;and e) the quantity of solventsused for cleaning operations shallbe kept on a daily basis.-When using add-on emissioncontrol equipment, maintain dailyrecords of key system operatingand maintenance data.-Any records required to bemaintained pursuant to the ruleshall be kept on site for at least 2years unless a longer retentionperiod is otherwise required bystate or federal regulation(s).Such records shall be readilyavailable for inspection andreview by the District.Submittal of an Annual ReportSubmittal of an annual report isrequired if a person holds apermit forapplying adhesiveproducts or sealant productssubject to the rule. The report isto include: 1) monthly recordsrequired by §O.4, 2) annualtotals,and 3) the name andaddress of thecompany oragency and PTO number.ApplicabilityThis rule is applicable to anyperson who supplies, sells, offersfor sale, or applies any adhesiveproduct, sealant product, orassociated solvent, used withinthe District.This rule is applicable to anyperson who supplies, sells, offersfor sale, manufactures, ordistributes any adhesive product,sealant product, or associatedsolvent for use within theDistrict, as well as any personwho uses, applies,orsolicits theuse or application of anyadhesive product, sealantproduct, or associated solventwithin the District.The provisions of this rule applyto any person who supplies, sells,offers for sale, manufactures,solicits the application of, or usesadhesives, sealants, sealantprimers or adhesive primers inVentura County.Exemptions-A stationary source that uses 20gallons or less of adhesivesproducts in a calendar year shallnot be subject to coating and-The rule does not apply to: 1)adhesives and associated solventsused in tire repair operations,provided a label on the adhesive-With the exception of Section K(Prohibition of Sales), the ruledoes not apply to any stationarysource that has total reactiveSTAFF REPORT–PARs 330, 337, 349, & 353Page J-42June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7solvent limits and work practices.-The following are exempt fromthe rule: 1)the use of adhesiveproducts or sealant productscontaining less than 20 gramsVOC per liter; 2) The use ofadhesives in tire repair providedthe label states “for tire repair useonly;” 3) The use of aerosol sprayadhesive products; 4) householdadhesive products subject toArticle 2, Consumer Products,Sections 94507-94517, Title 17,California Code of Regulations;5) contact adhesives that aresubject to the Consumer ProductSafety Commission regulations in16 CFR,Part 1302, that have aflash point greater than 20°F asdetermined pursuant to thoseregulations, and that are sold inpackages that contain 128 fluidounces or less; and 6) stripping ofcured adhesives, except thestripping of such materials fromspray application equipment.-The provisions of this rule,except for the work practicesrequired pursuant to Sections 5.3and 5.6 do not apply to: 1) Thetesting and evaluation ofadhesives in researchlaboratories, analyticallaboratories, or quality assurancelaboratories.- laboratoryoperators shall maintain monthlyrecords documenting the type andquantity of adhesive productsused and provide the records toused states "For Tire RepairOnly;" 2) adhesives andassociated solvents used in theassembly and manufacturing ofundersea-based weapon systems;3)solvent welding operations andassociated cleaning solvents usedin the manufacturing of medicaldevices, such as, but not limitedto, catheters, heart valves, bloodcardioplegia machines,tracheotomy tubes, bloodoxygenators, and cardiatoryreservoirs; 4) adhesive productand sealant product coatingoperations and associated solventuse subject to Rules 337 and 354;5)adhesive products and sealantproducts that contain less than 20grams of reactive organiccompound per liter (0.17 poundsof reactive organic compound pergallon) of adhesive or sealant,less water and less exemptcompounds, as applied; 6)cyanoacrylate adhesives; 7)adhesive products and sealantproducts, which are sold orsupplied by the manufacturer orsuppliers in containers of 16 fluidounces or less; and 8) adhesiveproducts (including aerosoladhesives) and sealant productssubject to the Air ResourcesBoard consumerproducts.regulation found in Title 17 ofthe California Code ofRegulations,section 94507etseq.organic compound emissions lessthan 200 pounds per calendaryear from adhesive productssealant products, and associatedsolvents.-ROC limits do not apply to: 1)assembly and manufacturing ofundersea-based weapon systems;2) testing and evaluation ofadhesive or sealant products inany research and development oranalytical laboratories; 3)weldingoperations andassociated cleaning solvents usedin the manufacturing of medicaldevices; 4) tire repair operations,provided a label on the adhesiveused states "For Tire RepairOnly;" 5) Manufacturingoperations of the followingproducts: diving suits, rubber fuelbladders, inflatable boats, lifepreservers or other productsdesigned for immersion inliquids. The adhesive productsused by these operations must belabeled "For the bonding ofimmersible products only;" 6)inkjet printerhead assemblyoperations where the ROCcontent of the adhesive used forlaminating is less than 100 gramsper liter of material; 7) thin filmlaminating operations ofmagnetic or electroniccomponents excluding inkjetprinter head assembly operations;and 8) glass bonding and primingprocesses in automotiveSTAFF REPORT–PARs 330, 337, 349, & 353Page J-43June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7the District upon request; 2) theuse of adhesives that are sold orsupplied with 8 fluid oz. or lessof adhesive in non-reusablecontainers; 3) the use of aerosoladhesive or aerosol adhesiveprimer products; 4) adhesiveproducts used in assembly, repair,or manufacture of undersea-basedweapon systems; 5) adhesiveproducts used in medicalequipment manufacturingoperations; 6) cyanoacrylateadhesive application processes;and 7) processes using polyesterbonding putties to assemblefiberglass parts at fiberglass boatmanufacturing facilities and atother reinforced plasticcomposite manufacturingfacilities.-A stationary source that uses 20gallons or less of sealant productsin a calendar year shall not besubject to coating and solventlimits and work practices.-The provisions of this rule,except for the work practicesrequired pursuant to Sections 5.3and 5.6 do not apply to the testingand evaluation of sealantproducts in research laboratories,analytical laboratories, or qualityassurance laboratories.Laboratory operators shallmaintain monthly recordsdocumenting the type andquantity of sealant products usedand provide the records to the-The rule’s coating limits andsolvent cleanup/surfacepreparation limits do not apply tomaterials used in laboratory testsand analyses,including qualityassurance and quality controlapplications, bench scaleprojects, or short-term (less than2 years) research anddevelopment projects.Recordsare to be kept when claiming thisexemption.-With the exception of Section K(Prohibition of Sales), the ruledoes not apply to any stationarysource that has total reactiveorganic compound emissions lessthan 200 pounds per calendaryear from adhesive productssealant products, and associatedsolvents.-The sales prohibitions haveseveral exemptions(e.g.,products being shipped outside ofthe County for use outside of theCounty, companies that haveinstalled add-on controls).-Solvents are exemptfrom therule (except for recordkeeping)that have two percentor lesscontent of ROC and TAC.-Thestripper/solventrequirementsdo not apply tosolvents and strippersused on:1)cotton swabs to removecottonseed oil before cleaning ofhigh-precision optics; 2) papergaskets;3) clutch assemblieswhere rubber is bonded to metalconvertible top manufacturingoperations.-The following specific adhesivesare exempt from the rule: 1) anyadhesive, primer, or sealant thatcontains less than 20 grams ofROC per liter of material; 2) anyaerosol adhesive; and 3) anycyanoacrylate or methacrylatebased adhesive.-The provisions of SubsectionB.3 (substrates or nonspecificoperations) do not apply to anyperson who uses less than 10gallons per rolling period(consisting of 12 consecutivecalendar months) per stationarysource of an adhesive, a sealant,or primer in a separateformulation provided the totalvolume of noncomplyingadhesives, sealants, or primers ata stationary source does notexceed 55 gallons per rollingperiod (consisting of 12consecutive calendar months). Ifa specific adhesive, sealant,sealant primer or adhesive primercan be defined under one of theproduct categories in SubsectionB.2 (specific applications), thenthis exemption does not apply.-Sell Through of Adhesives: Aperson may supply, sell, offer forsale, or apply a noncomplyingadhesive for up to 6 months afterthe applicable effective dateprovided that: 1) productcomplies with the ROC limit inSTAFF REPORT–PARs 330, 337, 349, & 353Page J-44June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7District upon request.-Except for the records requiredin Section 6.1.3, the prohibitionof sale in Section 5.7 (prohibitionof sale) shall not apply to: 1)adhesive products and sealantproducts shipped, supplied, orsold exclusively to personsoutside the District for useoutside the District; and 2)adhesive products and sealantproducts sold to any person whocomplies with the requirementsof Section 5.4 (add-on controlequipment).-The solvent ROC content limitsdo not apply to 1) cleaning ofsolar cells, laser hardware,scientific instruments, or highprecision optics; 2) cleaning inlaboratory tests and analyses, orbench scale or research anddevelopment projects; 3)cleaning of clutch assemblieswhererubber is bonded to metalby means of an adhesive; and 4)cleaning of paper-based gaskets.by means of an adhesive; 4)semiconductors andmicroelectromechanical devices(thin film deposition, vacuumdeposition, dry etching, metallift-off, and associatedmaintenance activities), 5)electronic components, 6) smallencasements for electroniccomponents, 7) parts,subassemblies, orassembliesexposed to strong oxidizers orreducers, 8) transparencies,polycarbonate, or glasssubstrates, 9) solar cells, laserhardware, scientific instruments,high-precision optics, telescopes,microscopes, and military fluidsystems, and 10)cleaning/stripping of personalprotective equipment.effect at the time of manufacture;2) product was manufacturedprior to the effective date; and 3)date of manufacture or a codeindicating that date is clearlydisplayed on the product. If amanufacturer uses a date code tojustify this sell-throughexemption, the manufacture shallfile an explanation of eachcodewith the Air Pollution ControlOfficer.STAFF REPORT–PARs 330, 337, 349, & 353Page J-45June 21, 2012Santa Barbara County APCDAdhesive and Sealant Performance Standards7Regulated ComponentSan Joaquin Valley UnifiedAPCD Rule 4653 (09/16/2010)8Santa Barbara County APCDRule 353 (Proposed)Ventura County APCD Rule74.20 (01/11/2005)7CommentsSection B.10 prohibits the use ofprimers, sealants, or adhesivesthat contain 1,1,1-trichloroethane(CAS 71-55-6) or methylenechloride (CAS 75-09-2).Exceptions to the prohibition onmethylene chloride are allowedfor plastic welding.Section F indicates: ViolationsFailure to comply with anyprovision of this rule, includingthe requirement to maintainrecords or supply VOC or ROCinformation, or supply ROCcomposite partial pressureinformation, shall constitute aviolation of this rule.Noncompliance determined byany test methodspecified orreferenced in this Rule is aviolation of this Rule. Wheremore than one approved testmethod may be applicable,sources shall not be required todemonstrate compliance usingmore than one approved testmethod.Clickhereto return to the list of Appendices in the Staff Report.THIS PAGE INTENTIONALLY LEFT BLANK

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page K-1 June 21, 2012

Santa Barbara County APCD Appendix K Santa Barbara County Impacts from the Revised Rules

Industry Impacts

The impacts from the revised rules will depend on the ty pe of parts, products, and equipment being cleaned and the cleaning processes employed. In general, the amended Rules 330, 349, and 353 will require the use of solvents with an ROC content of 25 grams per liter or less. For solven t cleaning operations requiring higher ROC contents to achieve greater degrees of cleanliness, an exemption has be en added to Rules 330, 337, 349, and 353. Generally, these exemptions are consistent with the industry standa rds and exemptions found in other air district rules.

Proposed amended Rule 337’s solvent cleaning requirements specify a source is to either meet a 200 g/l ROC content limit or comply with an ROC composite partial pressure of 45 mm Hg at 20 ° C. Further, when employing a solvent with an ROC content greater than 25 g/l, certain cleaning devices or methods ar e to be used (e.g., wipe cleaning, spray bottles, non-atomized solvent flow). The Dist rict anticipates that these provisions are easily met and there should be no impacts from them.

The Rule 337 stripper requirement ROC-cont ent limit is being lowered slightly. However, strippers currently in use (e.g., methylene chloride) meet the lowe r limit. Also, the lower polyester re sin monomer content limits proposed in Rule 349 should not cause impacts as these materials are generally in use and available in California.

Rules 337 and 353 will allow the use of higher ROC solvents when cleaning spray application equipment, provided an enclosed cleaning system is used. Some sources may need to purchase enclosed cleaning systems or switch to a low or no ROC cleaning material to comply. Hence, th ere may be purchasing costs ($500 to $2,800 per system) associated with new enclosed cleaning systems. The enclosed gun washer purchase costs will be offset by reduced labor costs and reduced solvent costs (p urchase and disposal). If a source is currently using IP A or MEK solvents, switching to acetone would result in neutral or a cost saving s for purchased solvent, respectively. And, by switching to acetone, the source would not need to modify the sp ray application equipment cleaning methods. (Acetone is a non-ROC, non-TAC cleaning material and is not subject to the District rules.)

The project includes a slight revision to Rule 321, Solv ent Cleaning Machines and Solvent Cleaning. The Rule 321.B.6 exemption change will clarify that solvent cleaning ma chines used in conjunction with one of the types of operations covered by the listed rules is not exempt from Ru le 321. There are no impacts anticipated from the rule revision beyond those indicated in the September 20, 2010 Staff Report for Rule 321.

The following provides impact information from the various rule revisions.

R ULE 

### 102, D EFINITIONS



### With the addition of four exempt compounds to the definition of reactive organic compounds , operators will have additional options for using comp ounds that will not be subject to the District’s new source review, prevention of significant deterioration, or prohibitory rule requirements.

R ULE 

### 202, E XEMPTIONS TO 

### R ULE 

### 201

The replacement of the EPA test method with the South Coast AQMD method addresses concerns about the sensitivity of the EPA tests when analyzing low-ROC solven ts. The District is unaware of any potential impacts due to changing the test method.

### STAFF REPORT

– PARs 330, 337, 349, & 353 Page K-2 June 21, 2012

Santa Barbara County APCD R ULE 

### 330, S URFACE 

### C OATING OF 

### M ETAL 

### P ARTS AND 

### P RODUCTS



### , R ULE 

### 337, S URFACE 

### C OATING OF 

### A EROSPACE


### V EHICLES AND 

### C OMPONENTS



### , R ULE 

### 349, P OLYESTER 

### R ESIN 

### O PERATIONS



### , AND 

### R ULE 

### 353, A DHESIVES AND


### S EALANTS



### Sources complying with the amended rule provisions may need to:

a. Replace the solvent used in solvent cleaning with a lower ROC- and/or lower TAC-content solvent;

b. Follow new or improved solvent handling techniques per the general operating requirements sections of the rules (Sections 330.F, 337.F, 349.D.3, and 353.J);

c. Modify their existing solvent cleaning techniques to be consistent with the new requirements (i.e., employ sanctioned devices and methods);

d. Change to a coating and polyester resin material that meet the lower ROC-content limits in Rules 337, 349, and 353; and/or

e. Implement enhanced recordkeeping procedures.

The District estimates that the increased costs for comply ing with the amended recordkeeping provisions will be about $1,000 per facility per year on the average. Also, there will likely be a slight increase in the administrative costs associated with preparing annual reports due to the ch anges in recordkeeping. Th is increase only affects permitted facilities and the District estimates it will be on the order of $200 to $300 per facility.

District Impacts

There should be minimal impacts to the District associated w ith the revised rules. Staff anticipates that the majority of the impacts from this rulemaking action will involve ou treach and education efforts and enforcement activities. These costs will be integrated into the District general compliance verification program.

Click here to return to the list of Appendices in the Staff Report.