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.” In 

2000, 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 specific 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, recordkeeping, reporting, 

source testing, and compliance provisions. 

RULE 337, SURFACE COATING OF 

AEROSPACE VEHICLES AND COMPONENTS 

In addition to the changes outlined 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 operations 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 responded 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 staff’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 information 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 Joaquin Valley Air Pollution Control District (APCD), Ventura 

County APCD, and the San Luis Obispo County APCD rules 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 summarized 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 comply 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. 

APPENDICES1

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, Solvent 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, revised 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 specific to a given rule are defined in that rule or in the 

first rule of the relevant regulation. Except as otherwise 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 aircraft, aerospace vehicle, satellite, or space 

vehicle.

[. . .]

“Capture Efficiency” means the percentage by weight of affected pollutants delivered to a control device 

divided by the weight of total affected pollutants generated by the source. 

[. . .]

“Carbon Adsorber” 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 any 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 are not limited to, platinum alloys, chromium, copper 

oxide, and cobalt. 

[. . .]

“Control Device” means any destruction and/or recovery equipment 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 boards, 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, charged 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 devices, 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 coating 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 purposes 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. Fluorinated gases include, but are not limited to: 

1. hexafluoroethane (C2F6), (CFC-116), 

2. octafluoropropane (C3F8), (PFC 218),

3. octafluorocyclopentene (C5F8), (PFC C-1418),

4. tetrafluoromethane (CF4), (CFC-14),

5. trifluoromethane (CHF3), (HFC-23),

6. difluoromethane (CH2F2), (HFC-32),

7. octafluorocyclobutane (c-C4F8), (RC 318),

8. octafuorotetrahydrofuran (C4F8O),

9. hexafluoro-1,3-butadiene (C4F6),

10. carbon fluoride oxide (COF2), 

11. nitrogen trifluoride (NF3), and

12. sulfur hexafluoride (SF6).

[. . .]

“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: 

 Ws - Ww - We

Grams of reactive organic compounds per liter of material = 

 Vm

Where: Ws = Weight of volatile compounds in grams 

 Ww = Weight of water in grams 

 We = 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] 

 Vm = 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 specific 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 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. 

[. . .]

“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 has 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; HCOOCH3

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 fluorinated ethers with no unsaturations, 

c. cyclic, branched, or linear, completely fluorinated 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; C6H12O2 (“acetic acid, 1,1-dimethylethyl ester”)

Tertiary-butyl acetate (also known as t-butyl 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 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) 

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

456. HFC-236fa (1,1,1,3,3,3-hexafluoropropane) 

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

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

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

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

501. HFC-365mfc (1,1,1,3,3-pentafluorobutane) 

52. HFE-7000; n-C3F7OCH3; (1,1,1,2,2,3,3-heptafluoro-3-methoxy-propane) 

513. HFE-7100; (CF3)2CFCF2OCH3; (2-(difluoromethoxymethyl)-1,1,1,2,3,3,3-heptafluoropropane) or 

C4F9OCH3; (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] 

524. HFE-7200; (CF3)2CFCF2OC2H5; (2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-heptafluoropropane) or 

C4F9OC2H5; (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 and 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 [(CF3)2CFCF2OCH3 or C4F9OC2H5]

Rule 202.D.10.l.2 requires an Authority to Construct and 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 amounts 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. Reactive organic compound composite pressure shall be 

calculated as follows: 

  

¦ ¦

¦

 

 

 

 n

e

n

i 1

w w e e i i

i

n

i

i i

c

W MW W MW W MW

W VP MW

PP

1

1

/ / /

/

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

Ww = Weight of water, in grams 

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

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

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

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

PPc = Reactive organic compound composite partial pressure at 20 degrees Celsius, in 

 millimeters of mercury 

VPi = 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 reagents, 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 contamination 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 are 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 owner 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 are 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 adjustments are acceptable, but if such openings are routine 

or if an access door remains open during the entire operation, 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 solids adhering to the object being coated to 

the weight of coating solids used in the application 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 the 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 routine 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; C6H12O2 ("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 source 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 (including 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 reactive 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 equipment (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 source 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 determining 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 byEnvironmental 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 approved by the Environmental Protection 

Agency, the Air Resources Board, and the Control Officer,; or

[. . .]

3. Wipe cleaning operations, provided that the solvents used do not exceed 55 gallons per year per 

stationary source and that the solvent cleaning complies 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 least 3 years and be made available to the District 

on request. Thereafter, the records shall be maintained 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 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. 

[. . .]

V. Storage and Transfer Equipment and Operations

[. . .]

2. Storage of refined fuel oils with an 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 numbers, add titles, and reformat the 

references in this manner.
THIS PAGE INTENTIONALLY LEFT BLANK
STAFF 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, machinery, 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 Vehicles 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 BLANK 
STAFF 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, Surface Coating of Metal Parts and Products 

RULE 330. SURFACE COATING OF METAL PARTS AND PRODUCTS. (Adopted 6/11/1979, 

revised 7/10/1990, 7/24/1990, 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 coatings, 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 operations 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 Rrule shall not apply to residential non-commercial metal parts and products coating 

operations. 

4. The provisions of tThis Rrule 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 tThis Rrule 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 tThis Rrule shall not apply to the coating operations listed below, which are 

covered under the categories rules cited. 

a. Aircraft or aAerospace vehicles 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 metal 

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 Rules 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 generic 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 microelectromechanical 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 assemblies 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, laser 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 compound 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 any fabricated part, processed part, 

assembly of parts, or completed unit of any aircraft including but not limited to airplanes, helicopters,

missiles, rockets, or and space vehicles includes satellites. 

2. “Air dDried” 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 object 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 coatings 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 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. 

“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 application 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 varnish definition is modeled on the SC 

Rule 1107 definition.

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 mechanical 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 Compounds per Liter of Coating, Less Water and Less Exempt 

Compounds” means the weight of reactive organic compounds per combined volume of reactive organic 

compounds and coating solids and can be calculated by the following equation: 

 

Grams of ROCreactive organic compounds Ws - Ww - Wes

per liter of coating, less water and less = 

exempt compounds Vm - Vw - Ves

 Where: Ws = Weight of volatile compounds in grams 

 Ww = Weight of water in grams 

 Wes = Weight of exempt organic compounds in grams 

 Vm = Volume of material in liters 

Vw = Volume of water in liters 

 Ves = 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 includes 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 organic 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, Definitions.

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 definition. 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, Architectural 

Coatings, uses the industrial 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-coating 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 reducer, 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 outside of a solvent cleaning machine, that uses solvent 

to remove uncured adhesives, uncured coatings, uncured inks, uncured polyester resin material, uncured 

sealant, or other contaminants, including, but not limited 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 cleaning 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, pails, and beakers with capacities of 3.785 liters (1.00 

gallon) or less are not considered solvent cleaning machines. However, the use of such a container or 

similar containers (e.g., hand-held spray bottles) with 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. 

“Texture Coating” means any coating that is applied to a metal part or product which, in its finished form, 

consists of discrete raised spots of the coating. 

13. “Touch-uUp 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 the application process, expressed as a percentage. 

D. Requirements -– Reactive Organic Compounds 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 Sections 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 approved 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 Section 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 least 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 introduction of material for mixing, use or storage the 

containers are empty, or doing maintenance/inspection of the containers.

2. All application equipment, ventilation system, and emission control equipment 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 licensed 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 or 

solvent 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. 

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 cleaning solvents to or from enclosed systems, vats, 

waste containers, and other cleaning operation equipment 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 recommendation 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, and 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 organic 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 materials 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 compounds-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 compounds 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-compliant coatings, all records required by Section H.1 

shall be summarized for each calendar year and submitted 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 equipment 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 Rule 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 uses 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 for shall be retained and available for inspection by the Control 

Officer or designated representative upon request for the previous 36-month periodand review by 

the District.

I. Requirements -– Compliance Provisions and Test Methods

1. Coatings 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 determining 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 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 through 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 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 85.5 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 weight,” or 2) “mass emission rates” (e.g., 

pounds per hour) shall first be approved by the 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 contaminant emissions that are not reactive organic 

compounds shall be determined by using the methods 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 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). 

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 Surface 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 not limited to, use of wipe cleaning cloths, hand-held 

spray bottles, squirt bottles, 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. 

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 subject 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 submitted to the District by 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.5, 

2. annual totals (gallons) based 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 BLANK
STAFF 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 Coating of Aerospace Vehicles and Components 

RULE 337. SURFACE COATING OF AIRCRAFT OR AEROSPACE VEHICLES 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 coatings 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. The provisions of this 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 generic 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 

narrow 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 surface 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 Technical Support Document

dated Sept. 20, 1995.)

Comment [A67]: Exempting aerosol coatings is 

consistent with the 1997 CTG for coating operations 

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 less 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 and 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 assemblies that are exposed to strong oxidizers or 

reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine);

c. Cleaning of aircraft transparencies, polycarbonate, or glass substrates;

d. Cleaning of solar cells, coated optics, laser hardware, scientific instruments, highprecision optics, telescopes, microscopes, avionic equipment, military fluid systems, and 

thermal control surfaces; 

e. Wipe cleaning during the manufacture, assembly, installation, maintenance, or testing of 

components of breathing oxygen systems that are exposed to the breathing oxygen; 

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

g. Wipe cleaning of aircraft and ground support 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 adhesive 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 County 

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 overspray from personal protective equipment; 

b. Wipe cleaning or stripping during fabrication, assembly, installation, and maintenance of 

upholstery, curtains, carpet, and other textile materials 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 maintenance 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 below. For purposes of this rule, the 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 surface to another surface by attachment or fused 

union. Adhesives are a type of specialty coating. 

1. “Adhesive Bonding Primer” means any 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, and 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 cleaning 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 relationship 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 order to facilitate bearing function or to protect base material from excessive 

wear. A material shall not be classified as a bearing coating if it can also be classified as a dry lubricative 

material or a solid film lubricant. 

“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 smooth exterior vehicle surfaces or fill cavities such 

as bolt hole accesses. A material shall not be classified as a caulking and smoothing compound if it can 

also be classified as a sealant. 

“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 component with a Type I or Type II etchant. Type I 

chemical milling maskants are used with a Type I etchant and Type II chemical milling maskants are used 

with a Type II etchant. This definition does not include bonding maskants, critical use and line 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 maskants (i.e., bonding, critical use and line sealer, and seal 

coat) are not included. Maskants that are defined as specialty coatings are not included 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 protection to the color coat. In some cases, a clear coat 

refers to any transparent coating 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 fuselage, such as wings and attached components, control 

surfaces, horizontal stabilizers, vertical fins, wing-to-body fairings, antennae, and landing gear and doors, 

for the purpose of extended corrosion protection and enhanced adhesion. 

“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 applied 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 solvent 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 restricted means for entry or exit (for example, fuel 

tanks, fuel vessels, and other spaces that have limited means 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 adhesive 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 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 contact between 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-forming 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 organic 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 oils 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 parts from strong acid or alkaline solutions such as 

those used in anodizing, plating, chemical milling and processing of magnesium, titanium, or high-strength 

steel, high-precision aluminum chemical milling of deep cuts, and aluminum chemical milling of complex 

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

included in this category. 

“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, media 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 Coatings” means an electrically conductive or insulative 

coating, or coatings used on radar and antennae enclosuresany 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 microwave regions. Uses include, but are not limited to, 

lightning strike protection, electromagnetic pulse 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 Electromagnetic Interference Coating” means any coating applied to 

space vehicles, missiles, aircraft radomes, and helicopter 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 application requires a minimum 60kV power supply. 

“Elevated-Temperature Skydrol-Resistant Commercial Primer” means any primer applied primarily to 

commercial aircraft (or commercial aircraft adapted for military use) that must withstand immersion in 

phosphate-ester (PE) hydraulic fluid (Skydrol 500b or equivalent) at the elevated temperature of 150 

degrees Fahrenheit for 1,000 hours. 

“Epoxy Polyamide Topcoat” means any coating used where harder films 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 where 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 adhesion 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 degree 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, Definitions.
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 aircraft fasteners, such as pins, collars, 

bolts, nuts, and rivets, with solid-film lubricants for distribution. 

“Fastener Sealant” means any sealant applied to a device used 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 passenger 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 requirements such as those needed for adhesive 

bond primed fastener heads or on surfaces expected to contain fuel. The flexible coating is required 

because it provides a compatible, flexible substrate over bonded sheet rubber and rubber-type coatings as 

well as a flexible bridge between the fasteners, skin, and skin-to-skin joints on outer aircraft skins. This 

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

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

“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 corrosion 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 pressure, 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 any 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 calculated by the following equation: 

Ws - Ww - Wes

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

Vm - Vw - Ves
STAFF 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 Ws - Ww - Wes

per liter of coating, less water and less = 

exempt compounds Vm - Vw - Ves

 Where: Ws = Weight of volatile compounds (including water) in grams 

 Ww = Weight of water in grams 

 Wes = Weight of exempt organic compounds in grams 

 Vm = Volume of material in liters 

Vw = Volume of water in liters 

Ves = Volume of exempt organic compounds in liters 

For aerospace coatings that contain reactive 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 Wrs - Wrw - Wre

per liter of coating, less water and less = 

exempt compounds Vrm - Vrw - Vre

 Where: Wrs = Weight of volatile compounds not consumed during curing in grams 

 Wrw = Weight of water not consumed during curing in grams 

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

Vrm = Volume of material not consumed during curing in liters 

Vrw = Volume of water not consumed during curing in liters 

Vre = 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 includes 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 any 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 inhabitable 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 airbrush 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 testing, 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 Coating” means a coating with a reactive organic 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 nonload bearing aerospace components in 

noncritical applications and is not covered in any other specialty adhesive categories. 

“Optical Anti-Reflective Coating” means any coating with a low reflectance in the infrared and visible 

wavelength ranges that is used for antireflection 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 acids 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 electromagnetic transmitters and receivers (e.g., 

radar, electronic countermeasures, etc.). 

“Rain Erosion-Resistant Coating” means any coating or coating system used to protect the leading edges 

of parts such as flaps, stabilizers, radomes, engine inlet 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, such 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 component 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 surface 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 maskant to improve abrasion and chemical 

resistance during production operations. 

19. “Sealant” means any coating material used to prevent the intrusion 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 sealants. 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 any coating topcoat that is applied directly to a part 

or product that is not subsequently overcoatedan uncoated aerospace vehicle or component for purposes of 

corrosion prevention, environmental protection, and functional fluid resistance. More than one layer of 

identical coating formulation may be applied to the vehicle or component. 

“Short Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the 

manufacturers’ required performance characteristics following 1,000 hours testing, used for metal to metal 

and metal to structural core bonding, and with an adhesive 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 atmospheric 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 organic compound or any toxic air contaminant, which 

is used as a diluent, thinner, dissolver, viscosity reducer, 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 outside of a solvent cleaning machine, that uses solvent 

to remove uncured adhesives, uncured coatings, uncured inks, uncured polyester resin material, uncured 

sealant, or other contaminants, including, but not limited 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 cleaning 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, pails, and beakers with capacities of 3.785 liters (1.00 

gallon) or less are not considered solvent cleaning machines. However, the use of such a container or 

similar containers (e.g., hand-held spray bottles) with 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 any 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 criteria beyond those of primers, topcoats, and selfpriming topcoats for specific applications. These performance criteria may include, but are not limited to, 

temperature or fire resistance, substrate compatibility, antireflection, temporary protection or marking, 

sealing, adhesively joining substrates, or enhanced corrosion protection. The reactive organic compound 

content limit for the individual specialty coatings are listed 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., debonding or unglueing), topcoats, and temporary protective 

coatings. 

24. “Structural Autoclavable Adhesive” means any coating adhesivewhich is applied for the 

purpose of bonding structural components together used 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 other 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 surface in preparation for the application of a coating. 

Comment [A96]: 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 [A97]: Modeled on 40 CFR 63.742 

and SJV Rule 4605 definitions. 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 any coating applied to a part to protect it from 

mechanical and environmental damage during manufacturing provide scratch or corrosion protection 

during manufacturing, storage, or transportation. Two types include peelable protective coatings and 

alkaline removable coatings. These materials are not intended 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 any 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 imperfections 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 imperfections 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 installed before the coating is cured. 

29. “Wing Coating” means any 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 

tables 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 Liter, 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 Liter, 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 Primers: 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 condensed 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 included 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 through 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 notapply 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 Sections 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 approved 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 exhaust 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 

than 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 Section 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 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, 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 sealant products with an as applied viscosity of 200 centipoise or 

greater, airless spray, air-assisted airless, 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 found in the SJV Rule 

4653 and the SC Rule 1168. The District proposes 

them to comply with the “every feasible control 

technique” requirements in state law. 

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 doing maintenance/inspection of the containers.

2. All application equipment, ventilation system, and emission control equipment 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 licensed 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 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 surface coating, stripper, 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, strippers, and cleaning solvents to or from enclosed 

systems, vats, waste containers, and other cleaning 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 recommendation 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 manufacturer’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 organic 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 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. 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 calendar year and submitted to the District by March 

1 of the following year.

5. Operators of facilities For any stationary source that uses 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 otherwise 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 representative 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 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.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 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 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 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 through 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 Decomposition 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 determining 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 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 85.5 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 weight,” or 2) “mass emission rates” (e.g., 

pounds per hour) shall first be approved by the 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 contaminant emissions that are not reactive organic 

compounds shall be determined by using the methods 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 1084-88, “Standard Test Methods for Viscosity of 

Adhesives,” ASTM International.

10. 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). 

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 components, including, but not limited to, use of wipe cleaning cloths, 

hand-held spray bottles, squirt bottles, 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 equally effective as an enclosed cleaning system 

at controlling emissions. “Equal effectiveness” of 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, except while dispensing solvent or replenishing 

the solvent supply, and where wipes are stored in closed containers to prevent 

evaporation when not in use; 

b. Application of solvent from hand-held spray bottles, squirt bottles, 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 all solvent runoff is collected in a manner that 

enables solvent recovery or disposal. The collection system shall be kept closed to 

prevent evaporation except while collecting solvent runoff or emptying the collection 

system. 

K. Compliance Schedule

Any person who owns, operates, or uses any application equipment to surface 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 

equipment 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 subject 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, annual 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 components.
THIS PAGE INTENTIONALLY LEFT BLANK
STAFF 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 

operations. 

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. Any 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 generic 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 microelectromechanical 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 assemblies 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, laser 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 operations 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 components, aerospace vehicles, aerospace vehicle components, 

aerospace vehicle payloads, or aerospace vehicle payload components. 

6. Section H shall not apply to polyester resin operations production or rework of products used in 

any laboratory tests or analyses, including quality assurance or quality control applications, bench 

scale projects, or short-term (less than 2 years) research 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 development 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 stripping 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 Rrule, 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 aerosol 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 translucent 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 mold 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 discharge to the atmosphere of reactive 

organic compound or toxic air contaminant emissions generated by a regulated operation. 

“Corrosion-Resistant Resin” means any polyester resin material used to make products for corrosion 

resistant applications such as, but not limited to, tooling, 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 include, 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-pressure 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 activity 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 cast 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 gel 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, but 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 polymerization; 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 surrounding air while the reinforcing fibers are saturated 

with resin. For the purpose of this rule, open molding 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 manufacture 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, bisphenol- 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, impregnating, injecting, forming, winding, spraying, and/or 

curing unsaturated polyester resin materials with fiberglass, fillers, or any other 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 surface 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 reducer, 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 outside of a solvent cleaning machine, that uses solvent 

to remove uncured adhesives, uncured coatings, uncured inks, uncured polyester resin material, uncured 

sealant, or other contaminants, including, but not limited 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 cleaning 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, pails, and beakers with capacities of 3.785 liters (1.00 

gallon) or less are not considered solvent cleaning machines. However, the use of such a container or 

similar containers (e.g., hand-held spray bottles) with 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 conjunction with fire retardant, corrosion 

resistant, or high-strength materials. 

20. “Specialty Resin” is means any halogenated, furan, bisphenol 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 build 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 paper 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 approved 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 operating guidelines. use only In addition, the 

application method employed shall be one of the following: 

a. aAirless, or 

b. aAir-assisted airless, or 

c. hHigh volume- low pressure spraying equipment, or 

d. eElectrostatic 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 unused 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 materials, 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 system, and emission control equipment shall be 

installed, operated, and maintained consistent 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 licensed 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 containers 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 cleaning 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 tests, “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.dshall 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 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 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 device efficiency for reactive organic compound 

emissions required in Section D.1.dshall 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 determine 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 the 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 contaminant emissions that are not reactive organic 

compounds shall be determined by using the methods 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 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 

Control Officer 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 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 the 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 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). 

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 mMaintain 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 

provides 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 used (e.g., airless, air-assisted airless, 

etc.); 

Comment [A155]: EPA recommended referring 

to SC Method 313 for determining 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 compound content of the solvent used and, when 

not using a closed mold system, the corresponding 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 each 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 compound 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 parameters 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 and 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 determination shall be in compliance by April 27, 1994. 

Any person who owns or operates any polyester resin 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 performing solvent cleaning associated with polyester resin 

operations, including, but not limited to, use of wipe cleaning cloths, hand-held spray bottles, squirt bottles, 

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 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 compliant 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 and 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/m2).

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 resin 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 minute. 

 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 plastic 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 hardened 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 m2grams per 

meter2.

5. CALCULATION 

 5.1 Volatile Organic Compound Emissions per Square Meter 

 (d/2)2 x 3.14

Area of Gallon Can Lid in m2 =

 10,000 cm2 / m2 

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 

cm2 = square centimeters 

m2 = square meters

 

 Volatile Organic Compound Losses, Grams per Square Meter =

 INITIAL WEIGHT - FINAL WEIGHT 

 Area of Sample Gallon Can Lid in Square Meters 
STAFF 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 sealant product for use within the District, as well as to 

any person who, or uses, applies, or solicits the use or application of any adhesives product, adhesive 

bonding primers, adhesive primers, sealants 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 Aadhesives 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 Aadhesives 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 Aadhesives products, adhesive 

bonding primers, adhesive primers, sealants, sealant primers products, and any associated 

solventor any other primers being tested or evaluated used in any laboratory tests or analyses, 

including quality assurance or quality control applications, 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 material or type of application, and the reactive 

organic compound content of each material. 

2)b. For each short-term research and development 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 Ssolvent 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, blood oxygenators, and cardiatory 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 Clean 

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 Aadhesives product and , adhesive bonding primers, adhesive primers, 

sealants, sealant primers product, or any other primers coating 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 Implementation Plan by the Environmental Protection 

Agency.

1)a. Rule 337, Surface Coating of Aircraft or Aerospace Vehicles Parts and 

ProductsComponents. 

2)b. Rule 354, Graphic Arts. 

g6. This rule shall not apply to Aadhesives 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 Ccyanoacrylate adhesives. 

i8. Except as otherwise specified in Section B.10.c, this rule shall not apply to Aadhesives 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, eExcept for Sections 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 products , adhesive bonding 

primers, adhesive primers, sealant products, associated solvents, and stripperssealant primers, or 

any other primers. applied at the stationary source 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 kept 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 installed 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 pound 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 generic 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 apply 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 microelectromechanical 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 are exposed to strong oxidizers 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, scientific 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 surface to another surface by attachment or fused 

union. 

“Adhesive Primer” means any product intended by the manufacturer 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 110o 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 for hand-held application without the need for ancillary 

hoses or spray equipment. “Aerosol adhesives” include “special purpose spray adhesives,” “mist spray 

adhesives,” and “web spray adhesives” as defined 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 homes, 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 definition. 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 definition; 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 into a substrate for protective, decorative, or 

functional purposes. Such materials include, but are not 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 adhesive 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 bond 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 contact between 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-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 capture system(s) and control device(s) used to 

reduce discharge to the atmosphere of reactive organic 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 definition. 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, such as a high boiling point organic solvent, that means 

is incorporated into an adhesive to increase its flexibility, workability, or distensibility, and may be 

determined using ASTM Method E260-9196(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 solids, and can be calculated by the following equation: 

Grams of ROCreactive organic compounds Ws ̶ Ww ̶ We

per liter of adhesive or sealant, less = 

water and less exempt compounds Vm ̶ Vw ̶ Ve

 Where: Ws = Weight of volatile compounds in grams 

 Ww = Weight of water in grams 

 We = Weight of exempt compounds in grams 

 Vm = Volume of material in liters 

 Vw = Volume of water in liters 

Ve = Volume of exempt compounds in liters

For adhesives or sealants that contain reactive diluents, the reactive organic compound content of the 

adhesive or sealant is determined after curing. The grams of reactive organic compound per liter of 

adhesive or sealant shall be calculated by the following equation: 

Grams of ROCreactive organic compounds Wrs ̶ Wrw ̶ Wre

per liter of adhesive or sealant, less = 

water and less exempt compounds Vrm ̶ Vrw ̶ Vre

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: Wrs = Weight of volatile compounds not consumed during curing in grams 

 Wrw = Weight of water not consumed during curing in grams 

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

 Vrm = Volume of material not consumed during curing in liters 

 Vrw = Volume of water not consumed during curing in liters 

Vre = 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: 

 Ws - Ww - We

Grams of ROC per liter of Material = 

 Vm

Where: Ws = weight of volatile compounds in grams 

Ww = weight of water in grams 

We = weight of exempt compounds in grams 

Vm = volume of material in liters 

“Hand Application Method” means the application of a surface coating by manually held nonmechanically operated equipment. Such equipment includes 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, vinyl tile, vinyl backed carpet, resilient sheet and roll, or 

artificial grass. Ceramic tile installation and the installation of perimeter 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 elastomeric urethane or molded rubber materials, in heater 

molding or casting processes, to fabricate products such 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-decorated hardboard (or tileboard), fiberglass 

reinforced plastic, and similar pre-decorated or non-decorated 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: 

 Wv

%ROCweightPercent reactive organic compound by weight = x100 

 W 

Where: Wv = 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 design 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 any foam constructed of plastics. 

“Plastics” means 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” means 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 materials 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 manufacturer 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 110o 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 edges 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 the installation or repair of singleply roof membrane to the edge of the roof and applying flashings to vents, pipes, or ducts that protrude 

through the membrane. Repair includes, but is not limited 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 organic compound or any toxic air contaminant, which 

is used as a diluent, thinner, dissolver, viscosity reducer, 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 outside of a solvent cleaning machine, that uses solvent 

to remove uncured adhesives, uncured coatings, uncured inks, uncured polyester resin material, uncured 

sealant, or other contaminants, including, but not limited 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 cleaning 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, pails, and beakers with capacities of 3.785 liters (1.00 

gallon) or less are not considered solvent cleaning machines. However, the use of such a container or 

similar containers (e.g., hand-held spray bottles) with a liquid solvent for cleaning is considered to be 
STAFF 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 remove cured or dried coatings such as primers, 

adhesives (e.g., debonding or unglueing), topcoats, and temporary protective coatings.

“Structural Glazing Adhesive” means any adhesive intended by the manufacturer to adhere glass, 

ceramic, metal, stone, or composite panels to exterior building frames. 

“Subfloor Installation” means the installation of subflooring material over floor joists, including the 

construction of any load bearing joists. Subflooring 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 production 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 manufacturer to be applied to the back of 

precure tread rubber and to the casing and cushion rubber. It may also be used to seal 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-butyl 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 requirements and will continue to be a reactive organic 

compound for purposes of all recordkeeping, 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 Products, 

or Adhesive Bonding Primers, Adhesive Primers, Sealant Products, Sealant Primers, or Any Other 

Primer

Except as provided in Sections E and I of this rule, ano person shall not apply nonaerosol adhesive

products, adhesive bonding primers, adhesive primers, or sealant products, 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 primers, 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

01/01/200008/19/1

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

01/01/200008/19/1

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

Products, Adhesive Bonding Primers, Adhesive Primers, or Sealant Products, 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

products, adhesive bonding primers, adhesive primers, or sealant products, 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 353-1, 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 PRODUCTS , ADHESIVE BONDING PRIMERS, ADHESIVE PRIMERS, AND 

SEALANT PRODUCTS, 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 products 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 products, adhesive bonding primers, adhesive primers, or uncured sealant

products, 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 degrees (°) 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 enclosed 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 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.

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 propane 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.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, 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 nonabsorbent 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, and emission control equipment 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 licensed 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 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 material 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 J.1. 

6. The handling and transfer of coatings, strippers, and cleaning solvents to or from enclosed 

systems, vats, waste containers, and other cleaning 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, and 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 adhesives 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 limits 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 supply, 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 products, adhesive bonding primers, adhesive primers, or sealant

products, 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 water 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-applied 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 products, adhesive

bonding primers, adhesive primers, sealant products, or associated solvent sealant primers, or any other 

primer, if such use or application results in a violation of the 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, 

nonaerosol adhesive products, 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 equivalent 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 D4457-1991, “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. 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 Products,” 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 determining 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

i 1

w w e e i i

i

n

i

i i

c

W Mw W Mw W Mw

W VP Mw

Pp

1

1

/ / /

/

Where : 

Ppc = VOC composite partial pressure at 20°C, in mm Hg. 

Wi = 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

We = Weight of the “i”th exempt compound, in grams, as determined by ASTM E260-96. 

Mwi = Molecular weight of the “i”th VOC compound, in grams per grams-mole, as given in 

chemical reference literature. 

Mww = Molecular weight of water, 18 grams per g - mole. 

MWe = Molecular weight of the “i”th exempt compound, in grams per g - mole, as given in 

chemical reference literature. 

VPi = 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 Pressure-Temperature Relationship and Initial 

Decomposition 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 reactive organic compound composite partial pressure, or an 

accepted scientific reference approved the Environmental 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; Elsevier 

Scientific 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 through 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 Carbon,” February 1991, or the South Coast Air Quality 

Management District Method 25.3, “Determination of Low Concentration Non-Methane NonEthane Organic Compound Emissions from Clean Fueled Combustion Sources,” March 2000, as

applicable. Environmental Protection 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 20qC degrees Celsius, and 

the minimum test temperature shall be 15qC 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 efficiencies 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 toxic 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 to convert “parts per million by volume” test method 

Comment [A203]: EPA recommended that the 

District 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 the 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 any 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., coating, 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 mixing 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. Tthe 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 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., 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 parameters values and 

maintenance procedures that demonstrate continuous 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 Section I, such as temperatures, pressures, 

and/or flow rates. 

d. The daily volume of each noncompliant adhesive, 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 data 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 Section 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 Control Officer, the Air Resources Board, and the 

Environmental Protection Agency, that has a coating transfer 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 adhesives 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 airless, 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 composite 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, and the Permit to Operate number that the adhesive 

products and/or sealant products application 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 Type Covered in Rules 330, 337, 349, and 351 

This appendix is provided to comply with the California 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 Surface 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 

RULE 201: Permits Required All emission units Emission of pollutants 

RULE 202: Exemptions to Rule 201 Applicable emission units Insignificant activities/emissions, 

per size/rating/function 

RULE 210: Fees All emission units Administrative 

RULE 212: Emission Statements All emission units Administrative 

RULE 302: Visible Emissions All emission units Particulate matter emissions 

RULE 303: Nuisance All emission units Emissions that can injure, 

damage, or offend. 

RULE 317: Organic Solvents All emission units Emission of pollutants 

RULE 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 

RULE 324: Disposal and 

Evaporation of Solvents 

All emission units Solvent disposal requirements 

REGULATION VIII: New Source 

Review

All emission units Addition of new equipment or 

modification to existing 

equipment. Applications to 

generate ERC Certificates. 

REGULATION XIII (RULES 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 community raised questions about the intent of certain rule 

provisions through discussions with staff and at the rule development public workshops. 

The following text provides clarification of rule 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 clean parts prior to painting. 

I-6

12 337 Add aerospace vehicle and component 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" for 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 period preceding the Board adoption hearing on the 

proposed rule changes, and staff’s response to these comments, will be presented to the District Board 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 solvents 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 source permit 

exemption 

I-12

31 - Sources for solvent ROC and toxic air contaminant data I-13

1. Scope of new solvent requirements (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 proposed. A slightly lower ROC 

content for strippers subject to Rules 337 or 353 is being proposed in response to an ARB comment. Additional 

information for each of these categories is provided below: 

Thinning: The rules limit the coating and 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 address 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 consistency 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 and 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. 

Click here to return to the Table of Contents. 
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. The 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 electronic 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 dispose 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 waste paints, solvents, and 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 manufacturers’ recommended 

amounts for each component and the manufacturers provide the “as applied” ROC content data for the mixed 

products. Will maintaining 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 required 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. 

Click here to return to the Table of Contents. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page I-4 

June 21, 2012 

Santa Barbara County APCD 

Question/Issue: Please explain what “readily available” means. 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 request 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 VOC 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 solvents 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 may require a source to have an independent laboratory 

perform a U.S.EPA Method 24 test to determine a product’s VOC content.

9. Do toluene, acetone, methanol, isopropanol, and methyl 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 include toluene, acetone, methanol, and isopropanol (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 product 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 such 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 toxic air contaminants. Toluene and isopropanol meet the 

ROC composite partial pressure limit of PAR 337. 

Click here to return to the Table of Contents. 
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 

Composite 

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 

Acetonea 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 cleaning/stripping ROC content and/or composite partial pressure limits 

in each of the proposed amended rules. 

Rule 330 Surface preparation and cleaning 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 equipment 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 likely 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 Systemb

330 25 Allowed Not an alternative 

compliance optionc

337 25 Allowed Allowed 

349 25 Allowed Not an alternative 

compliance optiona

353 25 Allowed Allowed 

Click here to return to the Table of Contents. 

 

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 machines to clean parts prior 

to painting (330.M, 337.M, 349.J, and 353.T). 

Question/Issue: We use solvent wash stations that have capacities greater than 1 gallon to clean application 

equipment. Will this activity be allowed under the proposed amended rules? 

Answer/Response: Yes, provided the equipment and its operation comply with the provisions of Rule 321. 

"Wash stations" are considered to be "cold cleaning machines." All solvent cleaning machines should comply 

with Rule 321 regardless of an overall process being subject 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 solvent 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 cleaning machine (degreaser). Is this allowed under the proposed amended 

rule? 

Answer/Response: Yes, provided the equipment and its operation comply with the provisions of Rule 321. For 

further details, see the previous 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 provisions to Rule 337. This is consistent with the EPA 

Control Techniques Guidelines for Coating Operations at Aerospace Manufacturing and Rework Operations. 

13. Aerospace ground support equipment provisions (337.A). 

Question/Issue: Satellite ground support equipment is sometimes refurbished (e.g., removal and replacement of 

insulation). The Rule 337 exemption provisions should extend 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 included 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 aircraft 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 integral equipment such as models, mock-ups, prototypes, 

molds, jigs, tooling, hardware jackets, and test coupons. Also included is auxiliary equipment associated 

with test, transport, and storage, which through 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 equipment not associated with space vehicles, the provisions 

of Rule 339, Motor Vehicle and Mobile Equipment Coating Operations, may apply. Ablative coatings on space 

vehicle launch pad equipment and structures are subject to Rule 337 provisions. 

14. Satellite coating application equipment 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 the cleaning of application equipment associated with 

applying satellite coatings. Since satellite coating operations are covered in Rule 337, this exemption seems out 

of place. 

Answer/Response: The District concurs and plans to delete 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 surface preparation (337.D.2 and J.1.a). However, per PAR 337.J.1.b, 

satellite coating application equipment cleaning will require either 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 vehicle or component excludes electronic components. 

But the Rule 321 definitions of aerospace vehicle and aerospace vehicle component 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 vehicles and aerospace vehicle components. 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 between adhesive primer (as defined in the compatible 

substrate primer definition) and adhesive bonding primer? 

Answer/Response: These terms stem from 40 CFR 63, Subpart GG and we defer to EPA for an explanation on 

their differences. 

“Adhesive Bonding Primer” means a primer applied in a thin film to aerospace 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 categories: “compatible epoxy primer” and “adhesive 

primer.” [. . .] “Adhesive primer” is a coating that (1) inhibits corrosion and serves as a primer applied to 

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

contain fuel. Fuel tank coatings are excluded from this category. 

17. Meaning of the word "new" for the "new commercial aircraft" limit in Table 337-2 (337.D.1). 

Question/Issue: Rule 337 has a category for new commercial 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 proposed adhesive limits in Rule 337? 

Answer/Response: They are found in proposed amended 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 Coating Operations at Aerospace Manufacturing 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 were 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 guidance on meeting the presumptive reasonably available 

control technology requirements to meet California's every 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 annotated 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 aircraft coatings that prevent the transmission of light? 

Answer/Response: PAR 337's definition of electric- or radiation-effect coating includes 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 coating 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 together requires special consideration. The process may 

involve cured or uncured adhesives. It overlaps the Rule 353 surface preparation and cleanup provisions. 

Answer/Response: The District agrees 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 partial 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 aerospace coatings from application equipment (337.J.1.b). 

Question/Issue: Cleaning application equipment that applies 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 the solvent ROC content does not exceed 25 grams per 

liter. 

24. Solvent cleaning of application equipment 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 cleaning machine or an air-tight solvent 

cleaning machine exclusively for cleaning application equipment. Airless and air-tight solvent cleaning 

machines are designed to remove the air inside the chamber before solvent 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 during 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 source 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 rule changes are intended to make the Rule 353.B.1.f.1 

exemption less ambiguous. The legislative intent of existing 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 adhesives 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 operations from Rule 353. These adhesive and sealant 

operations are subject to Rule 337. 

The District initially believed some portions of operations at C&D Aerospace and The Jet Center @ Santa 

Barbara would be subject to Rule 353. However, after 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 subject 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 equipment included in the Rule 353.B.13.i exemption from Section G.1, H, and 

R? 

Answer/Response: Without this exemption, avionic 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 electronic 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 for surface preparation, cleanup, 

and stripping operations associated with avionic equipment in Rule 353. 

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STAFF REPORT – PARs 330, 337, 349, & 353 Page I-12 

June 21, 2012 

Santa Barbara County APCD 

28. What surfaces are included in the requirements for cleanup 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 bonding 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 provision 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 solvents 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 adhesives 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 requiring 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, there will be a solvent costs 

savings. IPA and acetone solvent 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 gun washer costs or solvent cleaning machine modification 

costs if acetone is employed. 

30. Architectural coating permit exemption vs. the tertiary-butyl 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 where tBAc use exceeds 1 gallon per year per stationary 

source will trigger a permit if the bridge painted 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 operation is exempt by Rule 202.D.14. 

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STAFF REPORT – 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. 

Click here to return to the Table of Contents. 

Click here to return to the list of Appendices in the Staff Report.
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STAFF REPORT – PARs 330, 337, 349, & 353 Page J-1 

June 21, 2012 Santa Barbara County APCD 

Appendix J 

Santa Barbara County 

Comparison of the Adjoining Air District Rules 

that Apply to the Same Equipment or Source Type Covered in Rules 330, 337, 349, and 351 

To navigate to the aerospace vehicles and components performance standards click here (begins on page J-12), the polyester resin operation performance 

standards click here (begins on page J-24), or the adhesive and sealant performance standards click here (begins on page J-31). 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

General Coatings 

Baked Air Dried 

275 g/l 340 g/l 

275 g/l 340 g/l 

275 g/l 340 g/l 

275 g/l 275 g/l 

Multi-Component no listed below 

Baked Air Dried 

275 g/l 340 g/l 

Camouflage 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

360 g/l 420 g/l 

Electric Insulating Varnish 

Baked Air Dried 

620 g/l 620 g/l 

275 g/l 420 g/l 

Etching Filler 

Baked Air Dried 

720 g/l 720 g/l 

420 g/l 420 g/l 

Extreme High Gloss 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

Extreme Performance 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

275 g/l 420 g/l 

360 g/l 420 g/l 

Heat Resistant 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

360 g/l 420 g/l 

High Gloss 

Baked Air Dried 

360 g/l 420 g/l 

High Performance Architectural 

Baked 420 g/l 720 g/l 420 g/l 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-2 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

Air Dried 420 g/l 750 g/l 420 g/l 

High Temperature 

Baked Air Dried 

420 g/l 420 g/l 

720 g/l 720 g/l 

420 g/l 420 g/l 

Metallic Topcoat 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

360 g/l 420 g/l 

Military Specification 

Baked Air Dried 

275 g/l 420 g/l 

Mold Seal 

Baked Air Dried 

750 g/l 750 g/l 

420 g/l 420 g/l 

Pan Baking 

Baked Air Dried 

420 g/l 420 g/l 

Powder Coatings 50 g/l Prefabricated Architectural Component

Baked 

Air Dried 

275 g/l 

420 g/l 

Pretreatment Wash Primer 

Baked Air Dried 

420 g/l 420 g/l 

780 g/l 780 g/l 

275 g/l 340 g/l 

Repair 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

Silicone Release 

Baked Air Dried 

420 g/l 420 g/l 

420 g/l 420 g/l 

420 g/l 420 g/l 

Solar Absorbent 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

360 g/l 420 g/l 

Solid Film Lubricant 

Baked 880 g/l 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-3 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

Air Dried 880 g/l 

Touch-Up 

Baked Air Dried 

360 g/l 420 g/l 

360 g/l 420 g/l 

Vacuum Metalizing 

Baked Air Dried 

800 g/l 800 g/l 

420 g/l 420 g/l 

Zinc-Filled Primers 

Baked Air Dried 

420 g/l 420 g/l 

Application Equipment Electrostatic, 

electrodeposition, flow coat, roll coat, dip coat, HVLP, brush coat, continuous coat, hand application, or other approved method that can 

demonstrate at least 65% transfer efficiency. 

Electrostatic, flow coating, HVLP, or other approved method that can demonstrate 

at least 65% transfer efficiency. 

Electrostatic, electrodeposition, flow coat, roll coat, dip coat, HVLP, hand application, detailing or touch-up guns, or other approved method that can 

demonstrate at least 65% transfer efficiency. 

Electrostatic, flow coat, dip coat, HVLP, hand application, or other approved method that can 

demonstrate at least 65% transfer efficiency. 

Control Equipment Capture and control 

efficiency of 90% or greater. 

Use of the VOC emission control system shall not result in emissions in excess of those that would have been emitted had the operator complied with other applicable rule provisions. 

Control equipment shall result in the same or greater emission reduction as would compliance with the rule. 

Overall efficiency of 85.5% or greater. Use of the ROC 

emission control system shall not result in emissions in excess of those that would have been emitted had the operator complied with other applicable rule 

provisions.

Capture and control efficiency of 90% or greater. 

Surface Preparation/Cleanup Solvent

Surface preparation and cleanup solvents shall have an ROC content of 25 g/l or less.

Closed containers. Solvents shall have an ROC 

content of 25 g/l or less.

(Becomes effective one-year 

after adoption of the amended rule.) 

Surface preparation and cleanup solvents shall have an ROC content of 25 g/l or less.
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-4 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

Clean-Up Equipment, Cleaning of Application Equipment

Solvents shall have an ROC content of 25 g/l or less. 

Enclosed gun washer or equivalent APCO-approved 

gun washer when using a solvent with a composite vapor pressure < 45 mm HG at 20 degrees C. 

Solvents shall have an ROC content of 25 g/l or less. (Becomes effective one-year 

after adoption of the 

amended rule.)

Solvents shall have an ROC content of 25 g/l or less.

Evaporative Loss Minimization Closed containers for 

storage and disposal of solvent soaked rags and paper. Solvent containers must be closed when not in use. Minimize VOCcontaining materials spills and clean-up spills immediately.

Closed containers for storage and disposal of solvent soaked rags and paper. Solvent containers must be closed when not in use.

Closed containers for storage and disposal of ROC-containing materials 

(including cloth, paper, 

sand, etc.). Containers for ROC-contain materials must 

be closed when not in use. Minimize ROC-containing 

material spills and clean-up 

spills immediately. Dispose 

of wastes that contain ROCs by 1) a reclamation service, 2) a facility that treats, 

stores, or disposes of such wastes, or 3) recycling.Containers used to store ROC-containing materials 

shall be marked or clearly labeled indicating the name of the material they contain. 

Closed containers for storage and disposal of solvent soaked rags and paper. Solvent containers must be closed when not in use.

Recordkeeping Maintain records of VOC 

contents, mix ratios, coating 

categories used, coating and solvent use records. Maintain daily records of coating and solvent use. Keep record when using 

add-on emission control equipment.

-Have coating manufacturer's specification 

sheets, material safety data sheets (MSDS), or technical data sheets available for

review. -Maintain records showing the amount and type of coatings and solvent used on a monthly basis, VOC content of coating and 

-Maintain a current file of all ROC-containing materials that provides all information necessary to evaluate compliance, including: 1) material name and manufacturer ID, 2) application method, 3) material type, type operation, and for liquid coatings, the drying method 

-Maintain a current list of all coatings that provides all information necessary to evaluate compliance, including: 1) the name and manufacturer of each coating and any catalysts 

and reducers used with each coating, 2) mix ratio of components used in coatings, 3) ROC content of 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-5 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

solvents, application method, and amount of solvent disposed of or sent to a recycler.

and equipment coated, 4) specific mixing volumes of 

each components for each 

batch, 5) corresponding 

ROC content limit and as 

applied ROC content of 

materials used, and 6) current manufacturer's specification sheets, material safety data sheets (MSDS), product data sheets, or air 

quality data sheets, which lists the ROC content. available. Compliance with 

this provision may be done 

by ensuring the 

manufacturer’s specifications are listed on the product container.-Maintain records for each 

ROC-containing material 

purchased for use. The records shall include the 

following: 1) material name and manufacturer ID, and 2) 

material type.

-Maintain records of the disposal method each time 

waste solvent, waste solvent residue, or other waste 

material that contains ROCs is removed for disposal.-Keep monthly records of: 1) the volume of the ROCcontaining materials used, 2) 

ROC content of the materials, and 3) resulting 

coatings, as applied, and 4) coating category from §B.1 of each coating used.-Maintain records which shows the following for each ROC containing material used for cleanup, including equipment cleaning, and each ROC containing material used for substrate surface cleaning: 1) type, and 2) ROC content -Maintain records of the monthly volume of each complying coating and solvent used and daily volume of each noncompliant coatings used. 

-When using add-on 

emission control equipment, maintain daily records of 

key system operating and maintenance data.

-All lists and records shall be maintained for a minimum of 2 years from the date of entry and shall be available to the District. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-6 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

ROC emissions. -If claiming the §B.1 or exemption, maintain: 1) daily volumes of noncomplying coatings used by 

separate formulation, and 2) 

annual running totals of noncomplying coating volumes 

used for each separate formulation and all 

formulations.-When using add-on emission control equipment, maintain daily records of 

key system operating and maintenance data.

-Maintain records for 2 years unless otherwise required by state or federal regulations. Such records 

shall be available to the District. 

Submittal of an Annual Report Submittal of an annual 

report is required if a person: 1) holds a permit for equipment subject to the rule, or 2) a person is subject to the rule and applies noncomplying coatings. The 

report is to include: 1) monthly records required by §H.5, 2) annual totals, 3) if claiming the §B.1 exemption, the annual totals of non-complying coatings 

per §H.6.b, and 4) if permitted, the name and 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-7 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

address of the company or agency, and PTO number. 

Prohibition of Specification No person shall solicit or 

require for use or specify the application of a coating subject to this rule if such use or application results in a violation of any of the provisions of this rule. The prohibition of this Section shall apply to all written or oral contracts under the terms of which any coating is to be applied to any metal part or product at any physical location within the District.

A person shall not use, apply, or specify any coating for use on any metal part or product subject to the provisions of this Regulation which contains volatile organic compounds in excess of the Section D.1 limits, as applied.

No person shall specify, solicit or require theapplication of any coating to any metal part or product, or the use of any equipment 

cleaning solvent, if such 

application or use would violate this rule. This prohibition applies to all written and oral contracts for which any coating subject to 

this rule is to be applied to any metal part or product at any location in Ventura County.

Coating Compliance Statement or Labeling Requirements

Manufacturer of coatings and solvents must provide VOC concentration, mixing instructions, formulation information, and recommendations regarding thinning, redacting, or mixing with any other VOC containing materials, and express the coating VOC content on an as applied basis when used in accordance with the manufacturer's recommendations. 

Manufacturer of coatings and solvents must provide VOC concentration, mixing instructions, formulation information, and recommendations regarding thinning, redacting, or mixing with any other VOC containing materials, and express the coating VOC content on an as applied basis when used in accordance with the manufacturer's recommendations. 

Manufacturer of coatings and solvents must provide VOC concentration, mixing instructions, formulation information, and recommendations regarding thinning, redacting, or mixing with any other VOC containing materials, and express the coating VOC content on an as applied basis when used in accordance with the manufacturer's recommendations. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-8 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

Liquid Cleaning Material Compliance Statement or Labeling Requirements

Manufacturers of any solvents subject to this rule shall indicate on the solvent container, or on a separate product data sheet or material safety data sheet, the name of the solvent, manufacturer's name, the VOC content, and density of the solvent, as supplied. The VOC content shall be expressed in units of gm/liter or lb/gallon.

Manufacturer of liquid cleaning materials used in coating operations shall designate on product labels or data sheets: 1) VOC content as supplied, 2) recommendations regarding mixing with any other VOC containing materials, and 3) VOC content when used in accordance with the manufacturer's recommendation

Exemptions -Okay to use noncompliant 

coatings if usage is 55 gallons per rolling, consecutive 365-day period or less.-Rule does not apply to the application of coatings to aircraft, aerospace vehicles, marine vessels, can, coils, and magnetic wire and equipment subject to other prohibitory rules (4602, 4612, 4684).-The rule provisions do not apply to stripping of cured coatings, cured adhesives, and cured inks, except the stripping of such materials from spray application equipment.-The 25 g/l of VOC solvent limit does not apply to the 1) cleaning of solar cells, laser 

-Any coating used in volumes of less than 20 gallons in any calendar year is exempt from the coating VOC limit, provided that the source demonstrates that no complying coatings are available. Written approval must be obtained from the District. -Stationary sources using not more than four (4) gallons of paint, varnish, lacquer, thinner,and other solvent containing materials in any one day based on a monthly operating dayaverage, provided the recordkeeping requirements in Subsections E.1 and E.2 of this Rule are satisfied. -Stationary sources electing 

-Any non-complying coatings with separate formulation used in volumes of less than 20 gallons of each non-complying formulation per stationary source in any calendar year is exempt from the ROC limit. Coatings used for operations that are exempt per Sections B.2, B.3, B.4, B.5, B.6, B.10, and B.12

shall not be included in calculating the volume of coatings used under this exemption. To qualify for this exemption, the total 

volume of non-complying 

coatings at the stationary source shall not exceed 55 

gallons annually.

-The application method and recordkeeping requirements 

- Coating limits do not apply if there is no complying coating available and total usage of all noncomplying coatings has not exceeded 55 gallons in any calendar year.- This rule does not apply to: a. Aircraft or aerospace vehicle coating operations b. Marine vessel exteriors c. Motor vehicle and mobile equipment coating.d. Aerosol coating products. - The provisions of this rule, except Subsection B.8 (Prohibition of Specifications), shall not apply to any stationary source that emits less than 200 pounds of ROC in every rolling period of 12 consecutive calendar months 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-9 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

hardware, scientific instruments, or high precision optics; 2) cleaning in laboratory tests and analyses, or bench scale or research and development projects; 3) cleaning of paper-based gaskets; and 4) 

cleaning of clutch assemblies where rubber is bonded to metal by means of an adhesive.

-The 25 g/l of VOC solvent requirement does not apply to the cleaning of application equipment used to apply 1) coatings on satellites, or 2) radiation effect coatings. 

to utilize control equipment demonstrated to the satisfaction of the APCO to result in the same or greater emission reduction as would compliance with thisrule. Emissions, for the purpose of this exemption, shall be calculated on an hourly basis.-The application equipment requirements do not apply when a source can demonstrate to the satisfaction of the APCO that a transfer efficiency of 65% cannot be achieved or metallic coatings that contain more than 30 grams of metal particles per liter are used.

do not apply to touch-up and repair and texture coatings, 

provided the ROC-content 

limits are met and records are maintained pursuant to a PTO. 

-Operations exempt from the rule include: 1) residential 

noncommercial coating operations, 2) coating operations where the metal involved does not constitute a substantive part of the total surface area, 3) coatings 

supplied as aerosol products, 4) operations subject to other prohibitory rules, and 5) stripping (except when cleaning application equipment). -Solvents are exempt (except for recordkeeping) that have two percent or less content of ROC and TAC. -The following are exempt from coating ROC content limits and the application methods: 1) stencil coatings, 2) safetyindicating coatings, 3) magnetic data storage disk coatings, 4) solid-film lubricants and 5) electric insulating and thermal conducting coatings.- The solvent cleaning provisions shall not apply to: 

from metal parts and products coating operations. - The solvent cleaning provisions do not apply where total usage of noncomplying substrate surface cleaners does not exceed 5 galls per rolling 12-month period. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-10 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

1) semiconductors and microelectromechanical devices (thin film deposition, vacuum deposition, dry etching, metal lift-off, and associated 

maintenance activities), 2) electronic components, 3) small encasements for electronic components, 4) parts, subassemblies, or assemblies exposed to strong oxidizers or reducers, 5) transparencies, polycarbonate, or glass substrates, 6) solar cells, laser hardware, scientific instruments, high-precision 

optics, telescopes, microscopes, and military fluid systems, and 7) cleaning/stripping of personal protective equipment.

- The rule does not apply coatings that contain less 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. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-11 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Metal Parts and Products Performance Standards 

Regulated Component San Joaquin Valley Unified APCD Rule 4603 

(09/17/2009) 

San Luis Obispo County 

APCD Rule 411 

(01/28/1998) 

Santa Barbara County 

APCD Rule 330 (Proposed) 

Ventura County APCD Rule 

74.12 (04/08/2008) 

Applicability The provisions of this rule 

shall apply to the surface coating of metal parts or products, large appliances parts or products, metal furniture, and plastic parts and products, automotive/transportation and business machine plastic parts and products, and pleasure crafts, and to the organic solvent cleaning, and the storage and disposal of all solvents and waste solvent materials associated with such coating. 

This Rule is applicable to any person who applies or specifies the use of surface coatings to metalparts and products

This rule is applicable to any person who manufactures any metal part coating or 

product coating for use within the District, as well as any person who uses, 

applies, or solicits the use or application of any metal part or product coating or associated solvent within the District.

The provisions of this rule apply to any person who applies or specified the use of surface coatings to metal parts or products.

Comments The SJV Rule 4603 has 

exemptions and limits for the following that have been omitted from this analysis for brevity:-Dip coated steel joists,-Large appliance parts and products,-Metal furniture,-Plastic parts, and-Pleasure craft. 

The SBC Rule 330 only has a few coating categories. 

The specialty coating 

categories, which are specified in other air districts (e.g., pretreatment 

wash primer, high temperature, high gloss, etc.), are subject to the SBC 

Rule 330 general coatinglimits.
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-12 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

Ablative Coating2 After 12/31/2012: 600 600 Adhesion Promoter 850 850 - to become 250 (effective 24 

months after the date of adoption) 

850 

Adhesives 

Commercial Interior Adhesive2 760 Cyanoacrylate Adhesive2 1020 Fuel Tank Adhesive2 620 Non-Structural 250 250 250 Rocket Motor Bonding Adhesive2 890 Rubber-Based Adhesive2 850 Structural 

Autoclavable 50 50 50 Nonautoclavable 850 850 850 

Adhesive Bonding Primers 780 

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 

Antichafe Coatings 600 600 - to become 420 (effective 24 

months after the date of adoption) 

600 

Barrier Topcoat 420 420 420 Bearing Coating2 After 12/31/2012: 620 620 Caulking and Smoothing Compounds2 After 12/31/2012: 850 850 Chemical Agent-Resistant Coating2 After 12/31/2012: 550 550 Clear Topcoat 520 520 Commercial Exterior Aerodynamic Structure Primer2

350 

Compatible Substrate Primer2 350 Conformal Coating 750 750 Corrosion Prevention System Compound2 710 Cryogenic Flexible Primer2 350 Cryoprotective Coating2 600 

1 The San Luis Obispo County APCD is omitted from this table as they have no rule for this equipment/operation category. 2 This category is from the 1997 Control Techniques Guideline for Coating Operations at Aerospace Manufacturing and Rework Operations. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-13 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

Dry Lubricative Materials 

Fastener Manufacturing 120 120 250 Nonfastener Manufacturing 675 675 880 

Electric/Radiation Effect Coatings 800 800 800 Electrostatic Discharge and Electromagnetic Interference Coating2

After 12/31/2012: 800 800 

Elevated-Temperature Skydrol-Resistant Commercial Primer2

350 

Epoxy Polyamide Topcoat2 After 12/31/2012: 660 660 Exterior Primer3 350Extreme Performance Interior Topcoat2 420 Fastener Sealants 675 

After 12/31/2012: 600 

675 - to become 600 (effective 24 

months after the date of adoption) 

675 

Fire-Resistant (interior) Coating 600 Fire Resistant Coatings 

Civilian (Interior) 650 650 

Flexible Primer2 350 Flight Test Coatings Used on 

Missiles or Single-Use Target Craft 420 420 420 All others 600 600 600 

Fuel Tank Coating (Excluding Fuel Tank Adhesive)2

420 

Fuel Tank Coatings 420 

General 420 Epoxy 420 

Fuel Tank Adhesives 620 620 High Temperature Coating 850 720 850 Impact Resistant Coating 420 420 Insulation Covering2 740 Intermediate Release Coating2 750 Lacquer2 After 12/31/2012: 830 830 Maskants - Chemical Milling 250 250 Optical Anti-Reflective Coating 700 700 Maskants: 

3 The proposed amended Rule 337 lists this coating type in Table 337-1, Reactive Organic Compound Content Limits for Coatings Other than Specialty 

Coatings. The six coating types in that table were modeled on categories found in 40 CFR, Part 63, Subpart GG, National Emission Standards for Aerospace Manufacturing and Rework Facilities (Section 63.741 et seq.). Coatings types from this NESHAP are shown in bold. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-14 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

Bonding Maskant2 1,230 Critical Use and Line Sealer Maskant2 1,020 Seal Coat Maskant2 1,230 

Metallized Epoxy Coating2 After 12/31/2012: 740 700 Mold Release2 After 12/31/2012: 780 780 Optical Anti-Reflective Coating2 700 Part Marking Coating2 After 12/31/2012: 850 850 Pretreatment Coatings 780 780 780 Primer3 350Primers 

General 350 Commercial Exterior Aerodynamic Structure 350 350 

Primers Not Resistant to Phosphate Esters 350 Primers Resistant to Phosphate Esters Rain Erosion Resistant Coating 800 600 420 Rocket Motor Nozzle Coating After 12/31/2012: 660 660 Scale Inhibitor 880 880 880 Sealant 600 

Extrudable/Rollable/Brushable Sealant2 600 

After 12/31/2012: 280 

280 

Sprayable Sealant2 600 

Sealant Primer 720 Self-Priming Topcoat3 420Silicone Insulating Material After 12/31/2012: 850 850 Solid Film Lubricants 

Fastener Manufacturing 250 250 Fastener Installation 880 880 880 Nonfastener Manufacturing 880 880 880 

Space Vehicle Coatings 

Electrostatic Discharge Protection 800 800 800 Other Space Vehicle Coatings 1000 1000 1000 Adhesives 800 800 

Specialized Function Coating2 After 12/31/2012: 890 890 Temporary Protective Coatings 250 250 250 Thermal Control Coating2 After 12/31/2012: 800 800 Topcoat3 420Topcoats 420 420 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-15 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

Type I Chemical Milling Maskant3 250 Type II Chemical Milling Maskant3 160 Unicoats (Self Priming Topcoats) 420 420 Wet Fastener Installation Coating2 After 12/31/2012: 675 675 Wing Coating 750 750 420 Wire Coatings 

Electronic 420 420 Anti-Wicking 420 420 Pre-Bonding Etching 420 420 Phosphate Ester Resistant Ink 925 925 

Spray Application Equipment Transfer Requirements

Electrostatic, electrodeposition, flow coat, roll coat, dip coat, brush coat, or HVLP. In lieu of 

meeting this requirement add-on 

control equipment may be used. 

Electrostatic, electrodeposition, flow coat, roll coat, dip coat, HVLP, hand application, detailing or touch-up 

guns, or other approved method that 

can demonstrate at least 65% transfer efficiency. Specific 

provisions allow use of air-atomized 

spray for certain adhesives. 

Electrostatic, flow coat, dip coat, HVLP, hand application, or other approved method that 

can demonstrate at least 65% transfer efficiency. 

Control Equipment Capture and Control Efficiency

Overall capture and control efficiency of 85.5% or greater. 

Overall capture and control efficiency of 85.5% or greater. Compliance through the use of addon exhaust control equipment shall not result in affected pollutant emissions in excess of the affected 

pollutant emissions that would result from compliance with other 

applicable portions of the rule. 

Overall capture and control efficiency of 85% or greater. 

Solvent Use, Surface Preparation, and Clean Up The solvent is to contain less than 

200 grams of ROC per liter of material, as applied, or have an 

ROC composite partial pressure less than or equal to 45 mm Hg at 

a temperature of 20o C. In lieu of 

meeting this requirement add-on 

control equipment may be used. 

The following becomes effective one-year after adoption of the amended rule.: When performing surface preparation for coating application and cleanup (other than spray application equipment cleaning) the solvent is to contain 

less than 200 grams of ROC per liter of material, as applied, or have an 

ROC composite partial pressure less than or equal to 45 mm Hg at a 

temperature of 20 oC. 

No person shall use a solvent for surface cleaning, clean-up 

or engine gas path cleaning excluding stripping coatings or cleaning coating application equipment unless 1) contains 

less than 200 grams of ROC per liter of material, as 

applied, or 2) ROC composite 

partial pressure of the solvent is less than or equal to 25 mm Hg at a temperature of 20 oC. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-16 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

Except for solvent cleaning of spray application equipment, any person performing solvent cleaning with a solvent containing more than 25 grams per liter of material shall use one or more of the following cleaning devices or methods: 1) 

Wipe cleaning where solvent is dispensed to wipe cleaning materials from containers that are kept closed to prevent evaporation, except while dispensing solvent or replenishing the solvent supply; 2) Application of 

solvent from hand-held spray 

bottles, squirt bottles, or other closed containers with a capacity of one liter or less; or 3) Non-atomized solvent flow, dip, or flush cleaning method where pooling on surfaces being cleaned is prevented or drained, and all solvent runoff is collected in a manner that enables solvent recovery or disposal. The collection system shall be kept closed to prevent evaporation except while collecting solvent runoff or emptying the collection system. 

Evaporative Loss Minimization An operator shall store or dispose 

of fresh or spent solvents, waste solvent cleaning materials such as cloth, paper, etc., coatings, adhesives, catalysts, and thinners in closed, non-absorbent and nonleaking containers. The 

containers shall remain closed at all times except when depositing or removing the contents of the containers or when the container 

Closed containers for storage and disposal of ROC-containing materials (including cloth, paper, 

sand, etc.). Containers for ROCcontain materials must be closed 

when not in use. Minimize ROCcontaining material spills and cleanup spills immediately. Dispose of 

wastes that contain ROCs by 1) a reclamation service, 2) a facility that treats, stores, or disposes of such 

Closed containers shall be used for disposal and storage of cloth, paper, or other solvent-containing materials 

used for surface preparation, coating, cleanup, or paint removal.
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-17 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

is empty. wastes, or 3) recycling. Containers 

used to store ROC-containing materials shall be marked or clearly labeled indicating the name of the 

material they contain. 

Solvent Use, Cleaning of Application Equipment An operator shall not use VOCcontaining materials to clean 

spray equipment used for the application of coatings, adhesives, or ink, unless an enclosed system or equipment that is proven to be equally effective at controlling emissions is used for cleaning. If an enclosed system is used, it must totally enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining procedures, and it must be used according to the manufacturer’s recommendations and must be closed when not in use. In lieu of meeting this requirement add-on control equipment may be used. 

Use a solvent with an ROC content of 25 grams per liter. 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 equally effective as an enclosed cleaning system at controlling emissions. (Becomes 

effective one-year after adoption of 

the amended rule.)

Use of 1) an enclosed gun washer or "low emission spray 

gun cleaner" that has been approved in writing by the APCO, which is properly used 

for spray equipment cleaning, and 2) The ROC composite 

partial pressure of organic solvent used is less than 45 mm Hg at 20oC. 

Stripper No operator shall use or specify 

for use within the District a coating stripper unless it contains less than 300 grams of VOC per liter (2.5 lb/gal), as applied, or unless it has a VOC composite vapor pressure of 9.5 mm Hg (0.18 psia) or less at 68°F. In 

lieu of meeting this requirement 

add-on control equipment may be 

used. 

No person shall apply any stripper unless it contains less than 300 grams of ROC per liter, as applied, and/or unless its ROC composite partial pressure is 9.5 mm Hg or less 

at 20 oC. 

No person shall use a coating stripper unless it contains less than 300 grams of ROC per liter, as applied, or unless its ROC composite partial pressure is 9.5 mm Hg or less at 20 oC. 

Prohibition of Solicitation No person shall solicit, specify, 

or require an operator to use any coating, solvent, spray 

No person shall specify the use of any coating on any aerospace vehicle or component subject to the 

No person shall solicit, specify or require any other person to use in the District any coating, 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-18 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

equipment, or VOC emission control system that does not meet the limits or requirements of this rule.

provisions of this rule, which, as applied, contains reactive organic compounds in excess of the limits shown in the tables. No person shall specify the use of any stripper unless it complies with the provisions of the rule. 

adhesive, solvent, spray equipment, or control equipment that does not meet the limits or requirements of this rule.

Coating Labeling or Seller Information Requirements (Compliance Statement)

Coatings manufacturers shall display on product labels a statement recommending thinning (does not apply if thinning with water). The recommendation 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. Each 

container of any coating subject to the rule shall display the maximum 

reactive organic compound content of the coating, as applied, and after any thinning as recommended by the manufacturer. 

Coatings manufacturers shall designate on product labels or data sheets, the ROC content or the Volatile OrganicCompounds (VOC) content of coatings including coating reducers and catalysts, as supplied. This designation shall include recommendations regarding thinning, reducing, or mixing with any other ROC containing materials, and express the coating ROC or VOC content on an as applied basis when used in accordance with the manufacturer's recommendations. 

Liquid Cleaning Material Labeling or Seller Information Requirements (Compliance Statement)

The manufacturer of liquid cleaning materials used in coating operations shall designate on product labels or data sheets the ROC content and ROC Composite Partial Pressure of cleaning materials as supplied. This designation shall include recommendations regarding mixing with any other ROC 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-19 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

containing materials, and express the cleaning material ROC content when used in accordance with the manufacturer's recommendations. 

Recordkeeping Maintain records of ROC 

contents, mix ratios, daily usage 

records of coatings, adhesives 

strippers, and solvents and items 

coated. Also, for solvents, 

maintain a record of the vapor pressure. Okay to maintain monthly records of material use if 

only using complying materials. Keep record when using add-on 

emission control equipment.

-Maintain a current file of all ROCcontaining materials that provides all information necessary to evaluate compliance, including: 1) material name and manufacturer ID, 2) application method, 3) manufacturer’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 coatings operations, the coating type from Tables 337-1 or 337-2 and the type 

equipment coated, 4) specific mixing volumes of each components for each batch, 5) corresponding 

ROC content limit and as applied ROC content of materials used, and 6) current manufacturer's specification sheets, material safety data sheets (MSDS), product data sheets, or air quality data sheets, 

which lists the ROC content. available Compliance with this 

provision may be done by ensuring 

the manufacturer’s specifications are listed on the product container.

-Maintain records for each ROCcontaining material purchased for use. The records shall include the following: 1) material name and manufacturer ID, and 2) material 

type (e.g., coating type from Table 

Maintain records of ROC contents, mix ratios, daily usage records of coatings, adhesives strippers, and solvents. Also, for solvents, maintain records of the ROC composite partial pressure. Okay to maintain monthly records of material use if only 

using complying materials. Keep record when using addon emission control 

equipment.
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-20 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

337-1 or Table 337-2, cleanup solvent, stripper, etc.). - Maintain records of the disposal method each time waste solvent, waste solvent residue, or other waste material that contains ROCs is removed for disposal.-Keep monthly records of: 1) the 

volume of the ROC-containing 

materials used, 2) ROC content of 

the materials, and 3) resulting ROC emissions.

-If claiming the §B.1 exemption, maintain: 1) daily volumes of noncomplying coatings used by separate 

formulation, and 2) annual running 

totals of non-complying coating 

volumes used for each separate formulation and all formulations. -When using add-on emission control equipment, maintain daily 

records of key system operating and maintenance data.

-Any records required to be maintained pursuant to the 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 for inspection and review by the District. 

Submittal of an Annual Report Submittal of an annual report is 

required if a person: 1) holds a permit for equipment subject to the rule, or 2) a person is subject to the rule and applies non-complying coatings. The report is to include: 1) monthly records required by 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-21 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

§H.4, 2) annual totals, 3) if claiming the §B.1 exemption, the annual totals of non-complying coatings per 

§H.7.b, and 4) if permitted, the 

name and address of the company or 

agency, and PTO number. 

Applicability This rule shall apply to the 

manufacturing, assembling, coating, masking, bonding, paint stripping, surface cleaning, service, and maintenance of aerospace components, the cleanup of equipment, and the storage and disposal of solvents and waste solvent materials associated with these operations. 

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

or application of any aerospace vehicle or component coating or associated solvent within the District. Rule 337 does not apply to electronic components.

This rule is applicable to the manufacturing, assembling, coating, masking, bonding, paint stripping, and surface cleaning of aerospace components and the cleanup of equipment associated with these operations. Where Rule 74.12, Surface Coating of Metal Parts and Products, applies to the coating or cleaning of metal parts, including but not limited to tooling operations, this rule shall not apply. 

Exemptions -Jet engine or rocket engine 

flushing operations using any solvent other than trichloroethylene are exempt from this rule.- Except for the recordkeeping provisions of Sections 6.1.1 and 

6.1.4, the requirements of Section 5.0 shall not apply to aerospace assembly and component coating operations using not more than four (4) gallons of products containing VOCs per day. Solvent-containing materials used 

in operations subject to Rule 

4662 (Organic Solvent Degreasing Operations), shall not be included in this determination. 

-Any non-complying coatings with separate formulation used in volumes of less than 20 gallons of each of each non-complying formulation per stationary source in 

any calendar year is exempt from the ROC limit. To qualify for this exemption, the total volume of noncomplying coatings at the stationary source shall not exceed 200 gallons 

annually. Coatings used for 

operations that are exempt per Sections B.2, 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.

-The application method and recordkeeping requirements do not 

-Except for the prohibition of solicitation provisions, The rule does not apply to any stationary source that emits < 200 lbs in every rolling period of 12 consecutive monthsfrom assembly and component manufacturing operations. Emissions from cold cleaners, vapor degreasers, and aerosol products, shall not be included in this determination. -Coating limits do not apply to: any coating with separate 

formulations used in volumes 

of less than 20 gallons in any calendar year or any adhesive 

with separate formulations 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-22 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

Except for the provisions of Section 6.0, Section 5.0 shall not apply to laboratories which apply coatings, solvents, and adhesives to test specimens for purpose of research, development, quality control, and testing for production-related operations. 

Any person claiming this exemption shall provide operational records, data and calculations, as determined by the APCO to be necessary, to substantiate this claim. 

- Except for the provisions of Section 6.0, Section 5.0 shall not apply to laboratories which apply coatings, solvents, and adhesives to test specimens for purpose of research, development, quality control, and testing for production-related operations. Any person claiming this exemption shall provide operational records, data and calculations, as determined by the APCO to be necessary, to substantiate this claim.-The coating and adhesive limits do not apply to 1) Coatings or aerosols with separate formulations that are used in volumes of less than one (1) gallon on any day or 20 gallons in any calendar year at an aerospace assembly and component coating stationary source, or 2) Adhesives with separate formulations that are 

apply to touch-up and repair, provided Section D.1 limits are met and records are maintained pursuant to a PTO. -The provisions of the rule do not 

apply to coatings supplied as aerosol 

products. 

-Any coating and associated solvent cleaning 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. -Solvents are exempt (except for recordkeeping) that have two percent or less content of ROC and TAC.-The rule does not apply coatings 

that contain less 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. 

- Stripper and solvent requirements do not apply when performing space vehicle manufacturing and rework. -The rule does not apply to chemical milling and electrodeposition (except for electrodeposition of coatings). -The solvent cleaning provisions shall not apply to: 1) small encasements for electronic components, 2) parts, subassemblies, or assemblies exposed to strong oxidizers or reducers, 3) transparencies, 

used in volumes of less than 10 gallons in any calendar year at a stationary coating 

source, provided that the total 

volume of noncomplying coatings (excluding noncomplying adhesives) used at a stationary source does not exceed 200 gallons annually. In addition, a person claiming the 20 gallons of coating per year exemption shall notify the APCO in writing that substitute complying coatings are not available.

-Surface cleaning requirements do not apply to the cleaning of aerospace assembly and subassembly surfaces that are exposed to strong oxidizers or reducers such as nitrogen tetroxiode, liquid oxygen or hydrazine. -The coating transfer efficiency requirements do not apply to the application of coatings that contain less than 

20 grams of ROC per liter of coating less water and less exempt organic compounds. -The rule does not apply to 

aerosol coating products. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-23 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

used in volumes of less than one half (0.5) gallon on any day or ten (10) gallons in any calendar year at an aerospace assembly and component coating stationary source.--The coating transfer efficiency requirements do not apply to the application of coatings that 1) contain less than 20 grams of ROC per liter of coating less water and less exempt organic compounds, or 2) Are dispensed from 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 method requirements do not apply to 1) any situation that normally requires the use of an airbrush or an extension on the spray gun to properly reach limited access spaces, or 2) the use of airbrush application methods for stenciling, lettering, and other identification markings. -Section D.1, Table 337-1 chemical 

milling maskant limits shall not 

apply to: 1) touch-up of scratched 

surfaces or damaged maskant, and 2) touch-up of trimmed edges. 

-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.-The rule shall not apply to coatings (including adhesive 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.- Stripping/solvent requirements to do not apply to the cleaning of personal protective equipment.-wipe cleaning of breathing oxygen systems, surfaces prior to adhesive bonding, aircraft and ground support equipment that are exposed to fluid, 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-24 

June 21, 2012 Santa Barbara County APCD 

Surface Coating of Aerospace Vehicles and Components Performance Standards1

Regulated Component San Joaquin Valley Unified 

APCD Rule 4605 (06/16/2011) 

Santa Barbara County APCD Rule 

337 (Proposed) 

Ventura County APCD Rule 

74.13 (11/11/2003) 

fuel cells/tanks, confined spaces, associated with upholstery, curtains, and honeycomb cores. 

Comments Staff included definitions and 

coating categories from the 1997 Control Techniques Guidelines and the federal NESHAP for aerospace manufacturing and rework facilities. 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

General Polyester Resin Material or General Purpose Resin6

35% 35% 

Marble or Cultured Resins - VC Term Marble Resins - SJV Term 

After 12/31/2012: 10% or 32%, as supplied, with no fillers 

2-years after rule adoption: 10% or 32%, as supplied, with no fillers 

10% or 32% as supplied, no filler 

Solid Surface Resins After 12/31/2012: 17% 2-years after rule adoption: 17% 17% by weight monomer content. Tub/Shower Resins After 12/31/2012: 24% or 

35%, as supplied, with no fillers 

2-years after rule adoption: 24% or 35%, as supplied, with no fillers 

24% or 31% as supplied, no filler 

Lamination Resins After 12/31/2012: 31% or 

35%, as supplied, with no fillers 

2-years after rule adoption: 31% or 35%, as supplied, with no fillers 

31% or 35% as supplied, no filler 

Tooling Resin6

Atomized (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 Resin6 50% and use of low VOC 

polyester resins. 

50% 

Fire Retardant Resin After 12/31/2012: 38% 2-years after rule adoption: 38% 38% High Strength Materials After 12/31/2012: 40% 2-years after rule adoption: 40% 40% 

4 The San Luis Obispo County APCD is omitted from this table as they have no rule for this equipment/operation category. 5 The San Joaquin Valley Unified APCD Rule 4684 has special provisions for fiberglass boat manufacturing. Essentially those provisions require the use of a 

closed molding process and the monomer content limits shown in the table, coupled with solvent cleaning provisions, and solvent storage and disposal 

requirements. In lieu of meeting those provisions, there are various compliance options. For the purposes of brevity, additional details of the SJV Rule 4684 provisions on fiberglass boat manufacturing are omitted from this analysis. 

6 The monomer content of the material shall not be more than the percentages specified, by weight, as applied. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-25 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

Corrosion Resistant Resin After 12/31/2012: 48% 2-years after rule adoption: 48% 48% 

All Other Resin6 After 12/31/2012: 35% 2-years after rule adoption: 35% 35% Corrosion-Resistant Materials or Resins6 See Specialty Resins. See Specialty Resins. Fire Retardant Materials or Resin See Specialty Resins. See Specialty Resins. Tooling Gel Coat After 12/31/2012: 40% 2-years after rule adoption: 40% Gel Coat See Clear Gel Coat and 

Pigmented Gel Coat. 

See Clear Gel Coat and Pigmented Gel Coat. 

See Clear Gel Coat and Pigmented Gel Coat. 

Clear Gel Coat6 50% 50% 

Marble Resins After 12/31/2012: 40% 2-years after rule adoption: 40% 40% All Other Resins After 12/31/2012: 44% 2-years after rule adoption: 44% 44% 

Pigmented Gel Coat6 45% and use of low VOC 

pigmented gel coats. 

45% 

White and Off White After 12/31/2012: 40% 2-years after rule adoption: 30% 30% Non-White After 12/31/2012: 37% 2-years after rule adoption: 37% 37% Primer After 12/31/2012: 28% 2-years after rule adoption: 28% 28% 

Specialty Gel Coat After 12/31/2012: 48% Resin Containing Vapor Suppressant Weight 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 System Yes, no limit. Yes, no limit. Yes, no limit. Thinning or Diluting Prohibition Complying formulations shall not 

be thinned or diluted with any ROC or changed in any manner that may increase ROC emissions after testing, but prior to or during application. 

Spray Application Equipment Transfer Requirements

Spray application of polyester resin shall only be performed using airless, air assisted airless, high-volume, low-pressure (HVLP) spray equipment, or electrostatic spray equipment. High-Volume, Low-Pressure (HVLP) spray equipment shall be operated in accordance with the manufacturer’s recommendations. 

Spraying operation shall use only airless, air-assisted airless, high 

volume low pressure spray 

equipment, or electrostatic spray equipment as approved by the Control Officer and operated in accordance with the manufacturer's recommendations. 

Airless, air-assisted airless, electrostatic, or high volume-low 

pressure spray equipment shall be used in any spray application, except for touch-up or repair 

using a hand-held, air-atomized 

spray gun utilizing an attached resin container of no more than one quart capacity.

Control Equipment Capture and Control Efficiency 

90% overall capture and control efficiency or greater. 

85%, which becomes 90% two years after adoption, overall 

90% overall capture and control efficiency or greater. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-26 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

capture and control efficiency or greater. 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 the other applicable rule provisions. 

Solvent Use, Surface Preparation, and Clean Up All cleaning solvents (including 

product cleaning during manufacturing, surface preparation, and repair and maintenance cleaning) shall have an ROC content of 25 g/l or less. 

The following becomes effective one-year after adoption of the 

amended rule: All cleaning 

solvents (including productcleaning during manufacturing, surface preparation, and repair and maintenance cleaning) shall have an ROC content of 25 g/l or less. 

Cleaning material used on lines, rollers, brushes, spray equipment and personnel, shall be either a Clean Air Solvent or shall not exceed 25 grams ROC per liter of material as applied.

Evaporative Loss Minimization An owner or operator shall store 

or dispose of all uncured polyester resin materials, fresh or spent solvents, waste solvent cleaning materials such as cloth, paper, etc., coatings, adhesives, catalysts, and thinners in selfclosing, non-absorbent and nonleaking containers. The 

containers shall remain closed at all times except when depositing or removing the contents of the containers or when the container is empty. 

Closed containers for storage and disposal of ROC-containing materials (including cloth, paper, sand, etc.). Containers for ROCcontain materials must be closed when not in use. Minimize ROCcontaining materials spills and clean-up spills immediately. Dispose of wastes that contain ROCs by 1) a reclamation service, 2) a facility that treats, stores, or disposes of such wastes, or 3) recycling.

All materials containing reactive organic compounds, used or unused, including but not limited to semi-solid or liquid polyester 

resin materials and solid or liquid cleaning materials, shall be stored in closed containers and shall not leak.

Solvent Use, Cleaning of Application Equipment Solvents shall have an ROC 

content of 25 g/l or less.

Solvents shall have an ROC content of 25 g/l or less.(Becomes effective one-year after 

adoption of the amended rule.) 

Cleaning material used on lines, rollers, brushes, spray equipment and personnel, shall be either a Clean Air Solvent or shall not exceed 25 grams ROC per liter of 

material as applied. 

Recordkeeping -An operator subject to this rule Maintain records of 1) the type of Records shall contain: 1) 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-27 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

shall maintain the following records: 1) daily records of the type and quantity of all resins, gel coats, fillers, catalysts, and cleaning materials (including cleaning solvents) used in each operation, 2) records of the VOC content, in weight percent, of all polyester resin and gel coat, filler materials, including the weight percent of non-monomer VOC 

content of the resin and gel coat, used or stored at the stationary source, 3) records of the VOC content of all cleaning materials used and stored at the stationary source, and 4) records showing the weight loss per square meter during resin polymerization for each vapor-suppressed resin. 

-An operator claiming the 20 gallons per month exemption shall maintain records of polyester materials usage to support the claim of exemption. 

resin, catalyst, and cleaning materials used, 2) if applying polyester resin materials in spraying operations, the spray application method used (e.g., airless, air-assisted airless, etc.), 

3) for approved vapor suppressed resins, the weight loss in g/sq. m, monomer percent, and gel time, 4) if mixing solvents, specific 

solvent mixing volumes of each component for each batch, 5) the 

actual as applied ROC compound 

content of solvent and, when not 

using a closed mold system, the corresponding monomer content limits from Sections D.1.a, b, or c, and the actual as applied monomer contents, or if using a vapor suppressant the actual 

polyester or vinyl ester resin weight loss rate of the material used, and 6) current polyester 

resin material and solvent manufacturer's specification sheets, material safety data sheets (MSDS), product data sheets, or air quality data sheets, which lists 

the ROC content. Compliance with this provision may be done by ensuring the manufacturer’s specifications are listed on the product container.

-Maintain records for each ROCcontaining material purchased for use. The records shall include the following: 1) material name 

and manufacturer ID, and 2) material type. 

monthly reports (initialed by operator) of the manufacturer and product number of each polyester resin material and cleaning material used, 2) the monomer content in percent by weight of each polyester resin material used, both as applied and as supplied. For cleaning material, the ROC content in grams of ROC per liter of material as applied. Documentation shall be 

available to support these records. If using add-on control 

equipment, daily reports of the continuous control efficiency monitoring information. If claiming the 20 gallons per month exemption, in lieu of 1, 2, and 3 above, maintain monthly records of the amount of polyester resin material used.
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-28 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

- Maintain records of the disposal method each time waste solvent, waste solvent residue, or other waste material that contains ROCs is removed for disposal. -Keep monthly records of volumes used, polyester resin 

material as-applied monomer 

content and solvent ROC content, and resulting ROC emissions. -Maintain records when using add-on emission control equipment.-If claiming the §B.1 exemption, maintain monthly records of styrene volumes used to support the exemption claim.- Any records required to be maintained pursuant to the 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 for inspection and review by the District. 

Submittal of an Annual Report Submittal of an annual report is 

required if a person holds a permit for equipment subject to the rule. The report is to include: 1) monthly records required by §F.4, 2) annual totals, 3) if claiming the §B.1 exemption, the annual totals of styrene used per 

§F.6, and 4) the name and 

address of the company or agency and the PTO the polyester 

resin operation is subject to. 

Applicability Applicability The provisions of This rule shall apply to any This rule is applicable to the 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-29 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

this rule apply to commercial and industrial polyester resin operations, fiberglass boat manufacturing operations, and to the organic solvent cleaning, and the storage and disposal of all solvents and waste solvent materials associated with such operations. 

person owning or operating any commercial or industrial polyester resin operation.

manufacture of products from or the use of polyester resin material, including touch-up, repair and rework activities.

Exemptions -Other than the recordkeeping 

requirements, the provisions of 

this rule shall not apply polyester resin operation using less than 20 gallons per month of polyester resin material.

-The solvent cleaning provisions do not apply to 1) cleaning of solar cells, laser hardware, scientific instruments, or high precision optics, and 2) cleaning in laboratory tests and analyses, or bench scale or research and development projects.-Resins and gel coats used for touch up, repair, or small jobs, may have a monomer content limit up to 10% more than the applicable limit set forth in Table 1. Such resins or gel coats shall 

only be applied by a hand-held 

atomized spray gun which has a 

container for the resin or gel coat as part of the gun. Resins or gels 

applied by another method shall comply with the applicable limit 

in Table 1. Total material use for 

all small jobs at a facility shall 

not exceed two (2) gallons a day. 

-Polyester resin material limits do 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.-Solvents are exempt (except for recordkeeping) that have two percent or less content of ROC and TAC.-This rule shall not apply to polyester resin operations performed with polyester resin materials that contain no reactive organic compounds.-The solvent cleaning provisions shall not apply to: 1) semiconductors and microelectromechanical devices (thin film deposition, vacuum deposition, dry etching, metal lift-off, and 

associated maintenance activities), 2) electronic components, 3) small 

encasements for electronic components, 4) parts, subassemblies, or assemblies exposed to strong oxidizers or reducers, 5) transparencies, polycarbonate, or glass 

The provisions of Section B of this rule shall not apply to stationary sources using not more than 20 gallons per month of polyester resin material.
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-30 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

substrates, 6) solar cells, laser hardware, scientific instruments, high-precision optics, telescopes, 

microscopes, and military fluid systems, 7) cleaning/stripping of coating off of personal protective equipment, and 8) space vehicles. -Section H shall not apply to polyester resin operations 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 composite partial pressure of a 45 millimeter of mercury at 20 degrees Celsius: 1) satellites, 

satellite components, aerospace vehicles, aerospace vehicle 

components, aerospace vehicle payloads, or aerospace vehicle payload components.-Solvent cleaning shall not apply 

to polyester resin operations production or rework of products used in any laboratory tests or analyses, including quality 

assurance or quality control applications, bench scale projects, or short-term (less than 

2 years) research and development projects. Records are to be kept when claiming this exemption.

-Solvent cleaning shall not apply to cleaning/stripping of polyester resin material off of personal protective equipment. 

Comments Per ARB suggestions, we are: 1) 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-31 

June 21, 2012 Santa Barbara County APCD 

Polyester Resin Operations Performance Standards4

Regulated Component San Joaquin Valley Unified 

APCD Rule 4684 (06/16/2011)5

Santa Barbara County APCD 

Rule 349 (Proposed) 

Ventura County APCD Rule 

74.14 (04/12/2005) 

lowering the polyester resin material monomer content limits, 

and 2) increasing the emission control equipment efficiency. The District is also amending the 

rule’s solvent cleaning provisions 

per the 2010 Clean Air Plan commitment. 

Adhesive and Sealant Performance Standards7

Regulated Component San Joaquin Valley Unified 

APCD Rule 4653 (09/16/2010)8

Santa Barbara County APCD 

Rule 353 (Proposed) 

Ventura County APCD Rule 

74.20 (01/11/2005)7

ADHESIVES/SEALANT PRODUCTS - SPECIFIC APPLICATION LIMITS Adhesives 

ABS welding 400 (325) 400 400 Cellulosic plastic welding (100) Ceramic floor tile (65) 65 Ceramic tile installation 130 (65) 130 65 Computer diskette jacket manufacturing 850 Contact bond (contact adhesive) 250 (80) 250 80 Contact bond-specialty substrates 250 400 250 Cove base installation 150 (50) 150 50 CPVC welding 490 490 490 Drywall (50) 50 Elastomeric (750) Flexible vinyl (250) Floor covering installation (150) Indoor carpet or carpet pad (50) 50 Indoor floor covering installation (except ceramic tile installation) 

150 150 

Metal to urethane/rubber molding or casting 850 (250, effective 12 months 

7 The San Luis Obispo County APCD is omitted from this table as they have no rule for this equipment/operation category. 8 Rule 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 Best 

Available Control Technology guidance document for adhesives and sealants. Staff has attempted to show the SJV and VC limits for the categories that 

correspond to that model rule. The SJV Rule4653 has stricter requirements that go into effect on January 1, 2012. The values shown in parentheses reflect the limits that become effective in 2012. 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-32 

June 21, 2012 Santa Barbara County APCD 

Adhesive and Sealant Performance Standards7

Regulated Component San Joaquin Valley Unified 

APCD Rule 4653 (09/16/2010)8

Santa Barbara County APCD 

Rule 353 (Proposed) 

Ventura County APCD Rule 

74.20 (01/11/2005)7

after the date of amended rule 

adoption) 

Motor vehicle (250) Motor vehicle weatherstrip (750) Multipurpose construction (except cove base installation) 

200 (70) 200 (70, effective 12 months 

after the date of amended rule 

adoption) 

70 

Nonmembrane roof installation/repair 300 300 300 Other flooring 150 Other plastic cement welding 450 (250) 510 (250, effective 12 months 

after the date of amended rule 

adoption) 

500 

Outdoor floor covering installation (outdoor carpet) 

(150) 250 150 

Nonmembrane roof installation/repair (300) 300 300 Panel (50) 50 Perimeter bonded sheet vinyl flooring installation 

660 660 

Plastic cement welding (400) PVC welding 510 510 (500, effective 12 months 

after the date of amended rule 

adoption) 

Rubber flooring (60) 60 Rubber vulcanization 850 Sheet-applied rubber installation 850 850 Single-ply roof membrane installation/repair (250) 250 250 Staple and nail manufacturing 640 Structural glazing 100 100 100 Structural wood member (140) 140 Styrene-acrylonitrile welding (100) 100 Subfloor (50) 50 Thin metal laminating (780) 780 Tire retread 100 100 100 Top and Trim Adhesive (540) 540 Traffic marking tape (150) 150 150 VCT and asphalt tile (50) 50 Waterproof resorcinol glue 170 170 Wood flooring (100) 100 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-33 

June 21, 2012 Santa Barbara County APCD 

Adhesive and Sealant Performance Standards7

Regulated Component San Joaquin Valley Unified 

APCD Rule 4653 (09/16/2010)8

Santa Barbara County APCD 

Rule 353 (Proposed) 

Ventura County APCD Rule 

74.20 (01/11/2005)7

Sealants 

Architectural (250) 250 250 Marine deck (760) 760 760 Nonmembrane roof installation/repair (300) 300 300 Roadway (250) 250 250 Single-ply roof membrane (450) 450 450 Other (420) 420 420 

Adhesive Primers 250 

Automotive glass (700) 700 700 Plastic cement welding 650 650 Rubber vulcanization 850 Single-ply roof membrane 250 Traffic marking tape (150) 150 Other 250 250 Other plastic welding 500 

Sealant Primers 

Architectural – non porous (250) 250 250 Architectural – porous (775) 775 775 Marine deck (760) 760 460 Modified bituminous (500) Other (750) 750 760 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-34 

June 21, 2012 Santa Barbara County APCD 

Adhesive and Sealant Performance Standards7

Regulated Component San Joaquin Valley Unified 

APCD Rule 4653 (09/16/2010)8

Santa Barbara County APCD 

Rule 353 (Proposed) 

Ventura County APCD Rule 

74.20 (01/11/2005)7

NONSPECIFIC APPLICATIONS OF ADHESIVES/SEALANT PRODUCTS ONTO SUBSTRATES 

Flexible vinyl 250 250 Fiberglass (80) 200 (80, effective 12 months 

after the date of amended rule 

adoption) 

80 

Metal to metal 30 30 30 Plastic foam 120 (50) 50 Porous material 120 (50) 120 (50, effective 12 months 

after the date of amended rule 

adoption) 

Porous material (except wood and plastic foam) 50 Pre-formed rubber products 250 Reinforced plastic composite 250 (200) Rubber 250 Wood 30 30 Other substrates 250 250 

Thinning or Diluting Prohibition Spray Application Equipment Transfer Requirements

Electrostatic, electrodeposition, flow coat, roll coat, dip coat, HVLP, hand application, detailing or touch-up guns, or 

other approved method that can demonstrate a transfer efficiency equivalent to or greater than the HVLP efficiency. Specific provisions allow use of airatomized spray for certain 

adhesives. 

Electrostatic, electrodeposition, flow coat, roll coat, dip coat, HVLP, hand application, detailing or touch-up guns, or 

other approved method that can 

demonstrate at least 65% transfer efficiency. Specific provisions allow use of air-atomized spray 

for certain adhesives.

Solvent Use, Surface Preparation, and Clean Up Product Cleaning During 

Manufacturing Process and Surface Preparation : 1. General: 25 g/l of ROC2. Surface preparation before rubber vulcanization process: 850 g/lRepair and Maintenance Cleaning: 25 g/l of ROC 

Effective [one year from the date of amended rule adoption], except as provided in Section I (add-on control equipment), no 

person shall use any solvent containing more than 25 g/l ROC for the removal of uncured adhesive products or uncured sealant products from surfaces. 

Surface Preparation: -Single Ply Roof Membrane Installation: ROC Composite Partial Pressure ≤ 45 mm of Hg Partial Pressure at 20oC. -Inkjet Printer Head Assembly: ROC Content ≤ 200 g/l of material.-All Others: ROC Content ≤ 70 
STAFF REPORT – PARs 330, 337, 349, & 353 Page J-35 

June 21, 2012 Santa Barbara County APCD 

Adhesive and Sealant Performance Standards7

Regulated Component San Joaquin Valley Unified 

APCD Rule 4653 (09/16/2010)8

Santa Barbara County APCD 

Rule 353 (Proposed) 

Ventura County APCD Rule 

74.20 (01/11/2005)7

g/l of material. Cleanup (other than application equipment cleaning): ROC Composite Partial Pressure ≤ 45 mm of Hg Partial Pressure at 20oC. 

Evaporative Loss Minimization An operator shall store or dispose 

of adhesive products, sealant products, catalysts, thinners, fresh or spent solvents, and waste solvent materials such as cloth, paper, etc., in closed, nonabsorbent and non-leaking containers. The containers shall remain closed at all times except when depositing or removing the contents of the containers or when the container is empty. The containers used for disposal of adhesive materials, solvents, or any unused VOC containing materials shall be self-closing. 

Minimize VOC-containing 

materials spills and clean-up spills immediately. 

Closed containers for storage and disposal of ROC-containing materials (including cloth, paper, sand, etc.). Containers for ROCcontain materials must be closed when not in use. Minimize ROC-containing material spills 

and clean-up spills immediately. 

Dispose of wastes that contain ROCs by 1) a reclamation service, 2) a facility that treats, stores, or disposes of such wastes, or 3) recycling. Containers used to store ROCcontaining materials shall be marked or clearly labeled indicating the name of the material they contain.

All ROC-containing materials shall be stored in nonabsorbent, nonleaking containers, which shall be closed except when adding or removing materials. 

Solvent Use, Cleaning of Application Equipment 25 g/l of VOC. If cleaning 

application equipment used to apply rubber vulcanization primers or adhesives without addon controls, a solvent with a VOC content > 25 g/l and ≤ 850 g/l may be used if certain cleaning methods and prohibitions are followed. When using a VOC-containing material 

to clean spray equipment, an enclosed cleaning system shall be used.

Use a solvent with an ROC content of 25 grams per liter. 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 equally effective as an enclosed cleaning system at controlling emissions. (Becomes effective one-year after adoption of the 

amended rule.)

Use of 1) an enclosed gun washer or "low emission spray gun cleaner" that has been approved in writing by the APCO, which is properly used for spray equipment cleaning, and The ROC composite partial pressure of organic solvent used is less than 45 mm Hg at 20oC, or 2) A 

solvent ≤ 70 g/l ROC shall be used for cleaning, flushing or soaking of filters, flushing lines, pipes, pumps, and other parts of the application equipment. Parts 
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containing dried adhesive may be soaked in an organic solvent as long as the ROC composite partial pressure of the solvent is 9.5 mm Hg or less at 20 oC. 

Stripper The following becomes effective 

one-year after adoption of the 

amended rule: No person shall 

apply any stripper unless it 

contains less than 300 grams of 

ROC per liter, as applied, and/or unless its ROC composite partial pressure is 9.5 mm Hg or less at 

20 oC. 

No person shall use an adhesive stripper unless its ROC composite partial pressure is 9.5 mm Hg or less at 20 oC. 

Aerosol Adhesives Reactive Organic Compound Limit

Except as provided in Section I (use of add-on control equipment), no person shall use any aerosol adhesive unless the reactive organic compound content complies with the Air 

Resources Board consumer products regulation found in Title 17 of the California Code of Regulations, section 94507 et seq. 

Control Equipment Capture and Control Efficiency

Overall efficiency of 85% or greater. Use of the ROC emission control system shall not 

result in emissions in excess of those that would have been emitted had the operator complied with other applicable rule provisions. 

Overall efficiency of 85.5% or greater. Use of the ROC emission control system shall not result in emissions in excess of 

those that would have been emitted had the operator complied with other applicable rule provisions. 

Overall efficiency of 85% or greater. 

Prohibition of Sales Except as provided in Section 4.3 

(products shipped out of air district or sold to facilities with add-on controls), no person shall 

supply, sell, or offer for sale any adhesive product or sealant 

Except as provided in Section B.10, no person shall supply, sell, 

or offer for sale any: 1) adhesive 

product or sealant product that, at the time of sale, is defined under 

a product category in Table 353-

No person shall supply, sell, or offer for sale any adhesive, sealant or primer which, at the time of sale, is defined under a product category in Subsection B.2, and exceeds the ROC limits 
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product that does not meet the limits as specified in Section 5.1 (material VOC limits) or 5.4 (add-on control equipment limits).

1 and exceeds the reactive organic compound limit listed in Table 353-1, and 2) aerosol adhesive unless, at the time of sale, the provisions of the Air Resources Board consumer product regulation, found in Title 17 of the California Code of Regulations, section 94507 et seq., are met. 

listed in Subsection B.2 after the specified effective dates. This provision only applies to products that are supplied to or sold to persons within the District. The prohibition of sales does not apply when the sale is to a user 

that has add-on control 

equipment.

Prohibition Specification No person shall solicit, require 

for use, or specify the application of any adhesive products or sealant products, if such use or application results in a violation of the provisions of this Rule. This prohibition shall apply to all written or oral contracts.

No person shall solicit, require for use, or specify the application of any adhesive products, sealant products, or associated solvent if such use or application results in a violation of the provisions of this rule. This prohibition shall apply to all written or oral contracts. 

No person shall solicit, require for use, or specify the application of any adhesive, primer or sealant, if such use or application results in a violation of the provisions of this Rule. This prohibition shall apply to all written or oral contracts.

Manufacturer Compliance Statement or Labeling Requirements

Manufacturers of adhesive products, sealant products, and solvents shall label the materials: 1) VOC Content: Each container of adhesive product and sealant product subject to this rule shall display the maximum VOC content of the adhesive product or sealant product as applied. VOC content shall be displayed as grams of VOC per liter of adhesive product or sealant product, excluding water and exempt compounds, or grams of VOC per liter of material for lowsolids adhesive products. Each container of solvent subject to this rule shall display the maximum VOC content (in grams of VOC per liter of 

The manufacturer of any adhesive products or sealant products subject to this rule shall display the maximum volatile organic compound content as supplied, determined by the appropriate test method, on labels or containers. This designation 

shall display recommendations regarding thinning, reducing, or mixing with any other volatile organic compound containing material. This information shall include the maximum volatile organic compound content on an as-applied basis when used in 

accordance with the manufacturer's recommendations. 

The manufacturer of any adhesive, sealant, sealant primer or adhesive primer subject to this rule and manufactured after July 19, 1997, shall include a designation of the maximum ROC or VOC content as supplied, including adhesive components, expressed in grams per liter or pounds per gallon excluding water and exempt organic compounds from the appropriate test method, on containers and data sheets. This designation shall include recommendations regarding thinning, reducing, or mixing with any other ROC or VOCcontaining materials. This statement shall include the 
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material) as supplied; 2) each container of adhesive product or sealant product subject to this rule shall display a statement of the manufacturer's recommendations regarding thinning, reducing, or mixing of the adhesive product with any other VOC containing material. Mixing recommendations shall specify a ratio which results in a compliant, as applied, adhesive product, or sealant product; and 3) indicate on the solvent container, or on a separate product data sheet or material safety data sheet, the name of the solvent, manufacturer's name, the VOC content, and density of the solvent, as supplied. The VOC content shall be expressed in units of grams per liter or lb/gallon. 

maximum ROC or VOC on an as-applied basis when used in 

accordance with the manufacturer's recommendations. 

Liquid Cleaning Material Compliance Statement or Labeling Requirements

See above. The manufacturer of liquid 

cleaning materials subject to this rule shall designate on product containers and data sheets the ROC content and ROC Composite Partial Pressure of cleaning materials as supplied. This designation shall include recommendations regarding mixing with any other ROC containing materials, and express the cleaning material ROC content when used in accordance with the manufacturer's recommendations. All letters and numbers used to designate ROC 
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or VOC content on product labels shall be visible and legible. 

Sell-Through of Adhesives and Sealants 1) An adhesive product or sealant 

product manufactured prior to the effective date specified for that product in Section 5.1 (VOC limits), may be sold, supplied, or 

offered for sale for up to 12 months after the specified effective date.

2) An adhesive product or sealant product manufactured prior to the effective date specified for that product in Section 5.1 (VOC limits) may be applied up to 24 months after the specified effective date.1) and 2) above only apply to 

those adhesive products or sealant products which are labeled to display the date or date code indicating when the product was manufactured and that complied with the standards in 

effect at the time the product was manufactured. 

See exemptions. 

Recordkeeping An operator subject to the rule’s 

adhesive/sealant product VOC limits shall maintain the following records: 1) records of the VOC content, in grams VOC per liter, of all adhesive materials used and stored at the stationary source; 2) records of the VOC content of all solvents used and stored at the stationary source; and 3) effective on and after January 1, 2012, records of the 

-Maintain a current file of all ROC-containing materials that 

provides all information 

necessary to evaluate compliance, including: 1) material name and manufacturer ID; 2) application method; 3) material type, manufacturer’s specific use instructions (e.g., specific use for which the material is intended), type operation (e.g., coating, stripping, or solvent cleaning), 

As required by a District permit condition, maintain a file/records of ROC contents, mix ratios, and monthly usage rates of coatings, adhesives strippers, and solvents and items coated. Also, if complying with the ROC composite partial pressure, maintain a record of the ROC composite partial pressure. Keep daily records of non-compliant 

material use. Maintain records 
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VOC content, in grams VOC per liter, of all sealant materials used and stored at a stationary source. -An operator that claims an exemption from the prohibition of sales (i.e., materials shipped out of the air district or sold to customers with add-on controls) 

shall: 1) Keep a copy of the 

manufacturer’s product data sheet or material safety data sheet of the solvents used for organic solvent cleaning activities; and Name, address, and telephone number of the persons to whom the adhesive products or sealant products are sold.-Solvent cleaning records shall include: 1) manufacturer’s product data sheet or material safety data sheet of the solvents used for organic solvent cleaning activities; 2) a current list of solvents that are being used for organic solvent cleaning activities. The list shall include the following information: a) the name of the solvent and its manufacturer’s name; b) the VOC content of the solvent expressed in grams per liter or lb/gallon; c) when the solvent is a 

mixture of different materials that are blended by the operator, the 

mix ratio of the batch shall be recorded and the VOC content of the batch shall be calculated and recorded in order to determine compliance with the specified 

and for coating operations, the product type, type of substrate coated, and type of application (i.e., adhesive and sealant product type from Table 353-1 or Table 

353-2); 4) specific mixing 

volumes of each components for each batch, 5) corresponding ROC content limit and as applied ROC content of materials used; and 6) current manufacturer's specification sheets, material safety data sheets (MSDS), product data sheets, or air quality data sheets, which lists the ROC 

content. Compliance with this 

provision may be done by 

ensuring the manufacturer’s specifications are listed on the product container.-Maintain records for each ROCcontaining material purchased for use. The records shall include the following: 1) material name and manufacturer ID, and 2) material type (e.g., adhesive product and sealant product type from Tables 353-1 and 353-2, 

cleanup solvent, stripper, etc.). - Maintain records of the disposal method each time waste solvent, waste solvent residue, or other waste material that contains ROCs is removed for disposal. -Keep monthly records of: 1) the volume of the ROC-containing 

materials used, 2) ROC content of the materials, and 3) resulting ROC emissions. 

when using add-on emission control equipment. 
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limits of VOC content, as applied; d) the type of cleaning activity for each solvent that is being used in accordance with the applicable cleaning category specified in Table 6 of this rule; and e) the quantity of solvents used for cleaning operations shall be kept on a daily basis.

-When using add-on emission control equipment, maintain daily records of key system operating and maintenance data.

- Any records required to be maintained pursuant to the 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 for inspection and review by the District. 

Submittal of an Annual Report Submittal of an annual report is 

required if a person holds a permit for applying adhesive products or sealant products subject to the rule. The report is to include: 1) monthly records required by §O.4, 2) annual totals, and 3) the name and address of the company or agency and PTO number. 

Applicability This rule is applicable to any 

person who supplies, sells, offers for sale, or applies any adhesive product, sealant product, or associated solvent, used within the District.

This rule is applicable to any person who supplies, sells, offers for sale, manufactures, or distributes any adhesive product, sealant product, or associated solvent for use within the District, as well as any person who uses, applies, or solicits the 

use or application of any adhesive product, sealant product, or associated solvent within the District. 

The provisions of this rule apply to any person who supplies, sells, offers for sale, manufactures, solicits the application of, or uses adhesives, sealants, sealant primers or adhesive primers in Ventura County.

Exemptions -A stationary source that uses 20 

gallons or less of adhesives products in a calendar year shall not be subject to coating and 

-The rule does not apply to: 1) adhesives and associated solvents used in tire repair operations, provided a label on the adhesive 

-With the exception of Section K (Prohibition of Sales), the rule does not apply to any stationary source that has total reactive 
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solvent limits and work practices. -The following are exempt from the rule: 1) the use of adhesive 

products or sealant products containing less than 20 grams VOC per liter; 2) The use of adhesives in tire repair provided the label states “for tire repair use only;” 3) The use of aerosol spray adhesive products; 4) household adhesive products subject to Article 2, Consumer Products, Sections 94507 - 94517, Title 17, 

California Code of Regulations; 5) contact adhesives that are subject to the Consumer Product Safety Commission regulations in 16 CFR, Part 1302, that have a 

flash point greater than 20°F as determined pursuant to those regulations, and that are sold in packages that contain 128 fluid ounces or less; and 6) stripping of cured adhesives, except the stripping of such materials from spray application equipment. 

-The provisions of this rule, except for the work practices required pursuant to Sections 5.3 and 5.6 do not apply to: 1) The testing and evaluation of adhesives in research laboratories, analytical laboratories, or quality assurance laboratories.- laboratory operators shall maintain monthly records documenting the type and quantity of adhesive products used and provide the records to 

used states "For Tire Repair Only;" 2) adhesives and associated solvents used in the assembly and manufacturing of undersea-based weapon systems; 

3) solvent 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, blood oxygenators, and cardiatory reservoirs; 4) adhesive product and sealant product coating operations and associated solvent use subject to Rules 337 and 354; 5) adhesive products and sealant 

products 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; 6) cyanoacrylate adhesives; 7) adhesive products and sealant products, which are sold or supplied by the manufacturer or suppliers in containers of 16 fluid 

ounces or less; and 8) 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. 

organic compound emissions less than 200 pounds per calendar year from adhesive products sealant products, and associated solvents. 

-ROC limits do not apply to: 1) assembly and manufacturing of undersea-based weapon systems; 

2) testing and evaluation of adhesive or sealant products in any research and development or analytical laboratories; 3) 

welding operations and associated cleaning solvents used in the manufacturing of medical devices; 4) tire repair operations, provided a label on the adhesive used states "For Tire Repair Only;" 5) Manufacturing operations of the following products: diving suits, rubber fuel bladders, inflatable boats, life preservers or other products designed for immersion in liquids. The adhesive products used by these operations must be labeled "For the bonding of immersible products only;" 6) inkjet printer head assembly operations where the ROC content of the adhesive used for laminating is less than 100 grams per liter of material; 7) thin film laminating operations of magnetic or electronic components excluding inkjet printer head assembly operations; and 8) glass bonding and priming processes in automotive 
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the District upon request; 2) the use of adhesives that are sold or supplied with 8 fluid oz. or less of adhesive in non-reusable containers; 3) the use of aerosol adhesive or aerosol adhesive primer products; 4) adhesive products used in assembly, repair, or manufacture of undersea-based 

weapon systems; 5) adhesive products used in medical equipment manufacturing 

operations; 6) cyanoacrylate adhesive application processes; and 7) processes using polyester bonding putties to assemble fiberglass parts at fiberglass boat manufacturing facilities and at other reinforced plastic composite manufacturing facilities. -A stationary source that uses 20 gallons or less of sealant products in a calendar year shall not be subject to coating and solvent limits and work practices.-The provisions of this rule, except for the work practices required pursuant to Sections 5.3 and 5.6 do not apply to the testing and evaluation of sealant products in research laboratories, analytical laboratories, or quality assurance laboratories. Laboratory operators shall maintain monthly records documenting the type and quantity of sealant products used and provide the records to the 

-The rule’s coating limits and solvent cleanup/surface preparation limits do not apply to materials used in laboratory tests and analyses, including quality 

assurance and quality control applications, bench scale projects, or short-term (less than 

2 years) research and development projects. Records 

are to be kept when claiming this exemption.

-With the exception of Section K (Prohibition of Sales), the rule does not apply to any stationary source that has total reactive organic compound emissions less than 200 pounds per calendar year from adhesive products sealant products, and associated solvents. -The sales prohibitions have several exemptions (e.g., products being shipped outside of the County for use outside of the County, companies that have installed add-on controls). -Solvents are exempt from the 

rule (except for recordkeeping) that have two percent or less 

content of ROC and TAC. -The stripper/solvent requirements do not apply to solvents and strippers used on: 

1) cotton swabs to remove 

cottonseed oil before cleaning of high-precision optics; 2) paper 

gaskets; 3) clutch assemblies 

where rubber is bonded to metal 

convertible top manufacturing operations.-The following specific adhesives are exempt from the rule: 1) any adhesive, primer, or sealant that contains less than 20 grams of ROC per liter of material; 2) any aerosol adhesive; and 3) any cyanoacrylate or methacrylatebased adhesive.-The provisions of Subsection B.3 (substrates or nonspecific operations) do not apply to any person who uses less than 10 gallons per rolling period (consisting of 12 consecutive calendar months) per stationary source of an adhesive, a sealant, or primer in a separate formulation provided the total volume of noncomplying adhesives, sealants, or primers at a stationary source does not exceed 55 gallons per rolling period (consisting of 12 consecutive calendar months). If a specific adhesive, sealant, sealant primer or adhesive primer can be defined under one of the product categories in Subsection B.2 (specific applications), then this exemption does not apply. -Sell Through of Adhesives: A person may supply, sell, offer for sale, or apply a noncomplying adhesive for up to 6 months after the applicable effective date provided that: 1) product complies with the ROC limit in 
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District upon request. -Except for the records required in Section 6.1.3, the prohibition of sale in Section 5.7 (prohibition of sale) shall not apply to: 1) adhesive products and sealant products shipped, supplied, or sold exclusively to persons outside the District for use outside the District; and 2) adhesive products and sealant products sold to any person who complies with the requirements of Section 5.4 (add-on control 

equipment).

-The solvent ROC content limits do not apply to 1) cleaning of solar cells, laser hardware, scientific instruments, or highprecision optics; 2) cleaning in laboratory tests and analyses, or bench scale or research and development projects; 3) cleaning of clutch assemblies where rubber is bonded to metal 

by means of an adhesive; and 4) cleaning of paper-based gaskets. 

by means of an adhesive; 4) semiconductors and microelectromechanical devices (thin film deposition, vacuum deposition, dry etching, metal lift-off, and associated maintenance activities), 5) electronic components, 6) small encasements for electronic components, 7) parts, subassemblies, or assemblies exposed to strong oxidizers or reducers, 8) transparencies, polycarbonate, or glass substrates, 9) solar cells, laser hardware, scientific instruments, high-precision optics, telescopes, 

microscopes, and military fluid systems, and 10) cleaning/stripping of personal protective equipment.

effect at the time of manufacture; 2) product was manufactured prior to the effective date; and 3) date of manufacture or a code indicating that date is clearly displayed on the product. If a manufacturer uses a date code to justify this sell-through exemption, the manufacture shall file an explanation of each code 

with the Air Pollution Control Officer.
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Comments Section B.10 prohibits the use of 

primers, sealants, or adhesives that contain 1,1,1-trichloroethane 

(CAS 71-55-6) or methylene 

chloride (CAS 75-09-2). Exceptions to the prohibition on methylene chloride are allowed for plastic welding. Section F indicates: Violations Failure to comply with any provision of this rule, including the requirement to maintain records or supply VOC or ROC information, or supply ROC composite partial pressure information, shall constitute a violation of this rule. Noncompliance determined by any test method specified or referenced in this Rule is a violation of this Rule. Where more than one approved test method may be applicable, sources shall not be required to demonstrate compliance using more than one approved test method. 

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Appendix K 

Santa Barbara County 

Impacts from the Revised Rules 

Industry Impacts 

The impacts from the revised rules will depend on the type 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 solvent cleaning operations requiring higher ROC contents to 

achieve greater degrees of cleanliness, an exemption has been added to Rules 330, 337, 349, and 353. Generally, 

these exemptions are consistent with the industry standards 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 are to be used (e.g., wipe 

cleaning, spray bottles, non-atomized solvent flow). The District anticipates that these provisions are easily met and 

there should be no impacts from them. 

The Rule 337 stripper requirement ROC-content limit is being lowered slightly. However, strippers currently in use 

(e.g., methylene chloride) meet the lower limit. Also, the lower polyester resin 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, there 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 (purchase and disposal). If a source is currently using IPA or MEK solvents, 

switching to acetone would result in neutral or a cost savings for purchased solvent, respectively. And, by switching 

to acetone, the source would not need to modify the spray 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, Solvent Cleaning Machines and Solvent Cleaning. The Rule 

321.B.6 exemption change will clarify that solvent cleaning machines used in conjunction with one of the types of 

operations covered by the listed rules is not exempt from Rule 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. 

RULE 102, DEFINITIONS

With the addition of four exempt compounds to the definition of reactive organic compounds, operators will have 

additional options for using compounds that will not be subject to the District’s new source review, prevention of 

significant deterioration, or prohibitory rule requirements. 

RULE 202, EXEMPTIONS TO RULE 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 solvents. The District is unaware of any potential impacts due 

to changing the test method. 
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RULE 330, SURFACE COATING OF METAL PARTS AND PRODUCTS, RULE 337, SURFACE COATING OF AEROSPACE 

VEHICLES AND COMPONENTS, RULE 349, POLYESTER RESIN OPERATIONS, AND RULE 353, ADHESIVES AND 

SEALANTS

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 complying 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 changes in recordkeeping. This 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 with the revised rules. Staff anticipates that the majority 

of the impacts from this rulemaking action will involve outreach and education efforts and enforcement activities. 

These costs will be integrated into the District general compliance verification program. 

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