UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

 REGION IX AIR DIVISION 

Technical Support Document for EPA’s Direct Final Rulemaking for the 

California State Implementation Plan 

Ventura County Air Pollution Control District, Rule 74.24 Marine Coating Operations 

Prepared by Nancy Levin, April 14, 2014 
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RULE IDENTIFICATION 

Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP-Approved Rule: Rule 74.24, Marine Coating Operations; Adopted – 3/8/1994; Revised 

9/10/1996, 11/11/2003; Submitted – 4/26/05; Approved – 10/25/2005 (70 FR 61561). 

Subject of this TSD: Rule 74.24, Marine Coating Operations; Amended – 9/11/12; Submitted – 

4/22/13. 

RULE SUMMARY - Rule 74.24 establishes reactive organic compound (ROC) limits for 

application, use, and supply of coatings for marine and fresh water vessels, drilling vessels, and 

navigational aids, and their parts or components, including any parts subjected to unprotected 

shipboard conditions. It also includes requirements for add-on control equipment, surface 

preparation and cleanup solvents, recordkeeping, and test methods. 

Changes from the approved SIP rule include the following: 

1. Sections B.1 and B.2 – Added provision for low-solid coatings to be expressed on a 

“gram per liter of material” basis. Changed “VOC” to “ROC.” 

2. Section B.3 – Deleted provisions 3.b, 3.c, 3.d regarding monitoring combustion 

temperature, inlet and exhaust gas temperature, and control device efficiency to be 

consistent with 74.12. 

3. Section B.4 – Added “Cleanup” prior to the word “Solvent” to be consistent with 74.12. 

4. Section B.4 – Effective December 1, 2012, prohibited use of ROC-containing materials 

for cleanup or for spray equipment cleaning unless the ROC content is 25 grams per liter 

(g/l) of material or less. 

5. Section B.4 – Effective December 1, 2012, prohibited use of ROC-containing materials 

for substrate surface cleaning prior to coating that have more than 25 grams of ROC per 

liter of material. 

6. Section B.5 – Text changed to make consistent with Rule 74.12. 

7. Section B.7 – Added provision for low-solids coatings. 

8. Section B.8 – Added “or VOC” to text. 

9. Section C.5. – Deleted exemption for cleaning solvent in Section B.4.b. 

10. Section D – Text changed for various recordkeeping provisions. 

11. Section E – Various test methods updated. 

12. Section G – Various definitions updated. Definitions added for “Capture Efficiency,” 

“High Gloss Coating,” and “Low-Solids Coatings.” 

RULE EVALUATION CRITERIA - We primarily used the following criteria to evaluate the 

submitted rule: 

1. Enforceability – Section 110(a)(2)(A) of the Clean Air Act (CAA) requires that 

regulations submitted to EPA for incorporation into the SIP must be clear and legally 
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enforceable. The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA 

Region 9, August 21, 2001) were used to help evaluate compliance with the CAA 

§110(a)(2)(A) requirement for enforceability. 

2. Stringency – CAA section 172(c)(1) specifies that SIPs for nonattainment areas must 

include reasonably available control technology (RACT) for sources of emissions. 

Section 182(b)(2) specifically provides that for nonattainment areas classified as 

moderate or worse, states must revise their SIP to include RACT for sources of VOC 

emissions covered by a Control Techniques Guidelines (CTG) document issued after 

November 15, 1990 and prior to the area’s date of attainment. 

3. Non-interference – CAA §110(l) prohibits EPA from approving any SIP revision that 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the CAA. 

The VCAPCD regulates an area that is classified as nonattainment (serious) for the 1997 and 

2008 8-hour Ozone standards. Thus, submitted Rule 74.24 has to fulfill RACT requirements. 40 

C.F.R. § 81.305 (2010). 

We used EPA’s Control Techniques Guidelines for Shipbuilding and Ship Repair Operations 

(Surface Coating), 61 FR 44050 (Tuesday, August 27, 1996) (“Shipbuilding CTG”) and 40 

CFR Part 63, Subpart II - Volatile Organic HAP (VOHAP) Limits for Marine Coatings 

(“Shipbuilding NESHAP”) to evaluate this rule. In addition, we reviewed other state and local 

rules for this source category, including Bay Area Air Quality Management District (BAAQMD) 

Rule 8.43 -- Surface Preparation and Coating of Marine Vessels; South Coast Air Quality 

Management District (SCAQMD) Rule 1106 -- Marine Coating Operations; and San Diego 

County Air Pollution Control District (SDCAPCD) Rule 67.18 -- Marine Coating Operations. 

 

RULE EVALUATION 

1. Enforceability – The recordkeeping requirements, test methods, and other requirements 

generally ensure that the submitted rule can be enforced. Therefore, we believe that 

submitted Rule 74.24 is sufficiently clear and enforceable. 

2. Stringency – The rule is generally consistent with the limits and standards described in 

the Shipbuilding CTG, Shipbuilding NESHAP, and other state and local rules for this 

source category. However, based on our review, we believe Rule 74.24 could be 

further strengthened. Please see “Additional Recommendations” for details. 

3. Non-interference – Partly because of the reduced limits for clean-up solvents, we 

believe the submitted rule is more stringent than the version previously approved into 

the SIP, and, therefore, this rule would not interfere with any applicable requirement 

concerning attainment and reasonable further progress (RFP) or any other applicable 

requirement of the CAA. 
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RULE DEFICIENCIES – We have not identified deficiencies in submitted Rule 74.24 

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following revisions are not currently the basis for rule disapproval, but are recommended for the 

next time the rule is amended.

Lower coating limits 

1. Antifoulant Coatings (Aluminum Substrates) – 400 g/l (SC 1106, BA 8.43) 

2. High Gloss Coatings (Air Dried) – 340 g/l (SC 1106, BA 8.43) 

3. High Gloss Coatings (Baked) –275 g/l (SC 1106, BA 8.43) 

4. Pretreatment Wash Primer – 420 g/l (BA 8.43, SD 67.18) 

5. Underwater Weapons Systems (Baked) –275 g/l (SC 1106, BA 8.43, SD 67.18) 

Add or clarify VOC categories and coating limits 

The VOC limit table of Rule 74.24 does not include the following specialty coating categories 

that are provided in the Shipbuilding CTG: Mist; Nonskid; Nuclear; and Weld-through 

preconstruction primer. Rule 74.24 should be updated to include these categories and limits to 

meet current RACT levels the next time the rule is amended. 

Add definitions 

Define “Key System Operating and Maintenance procedures,” as used in paragraph D.1.d., and 

include specific example procedures in the definition. 

Clarify or revise exemptions

Rule 74.24 allows an exemption when “No complying coating or adhesive is available,” which is 

not provided for in the CTG. Please clarify the criteria the District uses to make this 

determination (e.g., not available within the District v. not sold in the U.S.). 

Retain deleted sections 3.b, 3.c, and 3.d regarding continuous monitoring of add-on control 

equipment 

The revised rule deletes former sections B.3. b, c, and d. regarding continuous monitoring of 

combustion temperature, inlet and exhaust gas temperature, and control device efficiency of addon control equipment. While the District indicates that it has “no sources currently using control 

equipment,”1

 and that if a source were to construct a control device, it would be subject to an 

Authority to Construct/Permit to Operate that requires monitoring of key operating parameters,2 

                                                            

1

 See VC 74.24 Strikeout version, October 29, 2012. 

2

 See Email from Stan Cowen, VCAPCD to Nancy Levin, EPA, Re: Rule 74.24 questions, April 14, 2014. 
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we recommend that the District retain these sections in the event that sources choose to operate 

emission control devices in the future. We note that the Rule currently contains recordkeeping 

requirements for emission control devices. 

EPA ACTION - EPA staff recommends approval of Rule 74.24 pursuant to CAA §110(k) (4) 

and §301(a). 

REFERENCES 

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., 

Bluebook) EPA OAQPS, May 25, 1988. 

(http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf). 

2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., 

Little Bluebook), EPA Region 9, August 21, 2001. 

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf) 

3. State Implementation Plans; General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 

28, 1992). 

4. Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface 

Coating), EPA, 61 FR 44050 (Tuesday, August 27, 1996). 

5. 40 CFR Part 63, Subpart II - Volatile Organic HAP (VOHAP) Limits for Marine 

Coatings. 

6. VCAPCD Rule 74.24 Marine Coatings Operations, 70 FR 61561 (10/25/2005). 

7. BAAQMD Rule 8.43 Surface Preparation and Coating of Marine Vessels, 68 FR 61753 

(October 30, 2003). 

8. SCAQMD Rule 1106 Marine Coating Operations, 60 FR 36227 (July 14, 1995). 

9. SDCAPCD Rule 67.18 Marine Coating Operations, 62 FR 14639 (March 27, 1997).