7/08 Rule 74.12: 1 VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 74.12 - SURFACE COATING OF METAL PARTS AND PRODUCTS (Adopted 11/19/85, Revised 8/26/86, 5/16/89, 11/17/92, 1/10/95, 9/10/96, 11/11/03, 4/8/08)

A. Applicability

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

Any person who applies or specifies the a pplication of surface coatings to either stationary structures or thei r appurtenances is subject to Rule 74.2 instead of this rule.

Any person who applies or specifies the application of surface coatings to aerospace vehicles or components is subject to Rule 74.13 instead of this rule.

Any person who applies or specifies the appli cation of surface coatings to motor vehicles or mobile equipment or their parts or compone nts is subject to Rule 74.18 instead of this

rule.

Any person who applies or specifies the appli cation of surface coatings to marine or fresh water vessels or their parts or components is subject to Rule 74.24 instead of this rule.

Any person who applies or specifies the app lication of surface coatings to pleasure craft or their parts or components or commercial boatyar d operations is subject to Rule 74.24.1

instead of this rule.

B. Requirements

1. Coating Reactive Organic Com pounds (ROC) Content Limits: On or before July 7, 2008, no person shall apply any coating w ith an ROC content in excess of the following limits, as applied:

ROC Limits Grams Per Liter (g/L), or Pounds per Gallon (lb/gal) of Coating, Less Water and Exempt Organic Compounds

Air Dried Baked Coating g/L lb/gal g/L lb/gal

All coatings except 340 2.8 275 2.3 for the following:

Camouflage 420 3.5 360 3.0

Extreme Performance 420 3.5 360 3.07/08 Rule 74.12: 2 Etching Filler 420 3.5 420 3.5

Heat Resistant 420 3.5 360 3.0 High Gloss 420 3.5 360 3.0 High Performance

Architectural 420 3.5 420 3.5 High Temperature 420 3.5 420 3.5 Laboratory Furniture 340 2.8 340 2.8

Metallic 420 3.5 360 3.0

Mold Seal 420 3.5 420 3.5 Pan Backing 420 3.5 420 3.5

Pretreatment Wash Primer 340 2.8 275 2.3

Silicone Release 420 3.5 420 3.5

Solar Absorbent 420 3.5 360 3.0 Vacuum Metalizing 420 3.5 420 3.5

After July 7, 2008, no person shall apply an y coating with an ROC content in excess of the following limits, as applied:

ROC Limits Grams Per Liter (g/L), or Pounds per Gallon (lb/gal) of Coating, Less Water and Exempt Organic Compounds

Air Dried Baked Coating g/L lb/gal g/L lb/gal

All coatings except 275 2.3 275 2.3 for the following:

Multi-Component

not listed below 340 2.8 275 2.3 Camouflage 420 3.5 360 3.0

Extreme Performance 420 3.5 360 3.0 Etching Filler 420 3.5 420 3.5

Heat Resistant 420 3.5 360 3.0 High Gloss (Multi-Component) 420 3.5 360 3.0 High Performance

Architectural 420 3.5 420 3.5 High Temperature 420 3.5 420 3.5

Metallic 420 3.5 360 3.0

Mold Seal 420 3.5 420 3.5 Pan Backing 420 3.5 420 3.5

Pretreatment Wash Primer 340 2.8 275 2.3

Silicone Release 420 3.5 420 3.5

Solar Absorbent 420 3.5 360 3.07/08 Rule 74.12: 3 Vacuum Metalizing 420 3.5 420 3.5

2. Add-on Control Equipment Option: In lieu of complying with the coating ROC content limits specified in Subsection B.1, air pollution control equipment may be used provided:

a. The combined capture and control de vice efficiency re duces emissions by at least 90 percent by weight, and

b. The Air Pollution Control Officer (APCO) issues written approval for such equipment in the form of an Authority to Construct and Permit to Operate, and

c. When operating a thermal incinerator, the combustion temperature of the incinerator is continuously monitored.

d. When operating a catalytic incinerator, the exhaust and inlet gas temperatures of the incinerator are continuously monitored, and

e. When operating a carbon adsorber or control device other than a thermal or catalytic incinerator, the contro l device efficiency is continuously monitored, and

f. The equipment and monitors are used in accordance with vendor or manufacturer specifications.

3. Transfer Efficiency: No person shall apply coatings subject to this rule except by using properly operated equi pment and by using one or more of the following:

a. Electrostatic application, operated at a minimum of 60 kV;

b. Flow coat application;

c. Dip coat application;

d. High volume, low pressu re application (HVLP);

e. Hand application methods;

f. Any other application method that is demonstrated to achieve at least 65 percent transfer efficiency.7/08 Rule 74.12: 4 4. Surface Preparation and Cleanup:

a. After July 7, 2008, no person shall us e a material for substrate surface cleaning that has an ROC content ex ceeding 25 grams per liter of material.

On or before July 7, 2008, no person sh all use any material which contains more than 70 grams of ROC per liter of material for substrate surface cleaning. Substrate surface cleaning performed in a degreasing unit shall not be subject to this ROC content limit.

b. After July 7, 2008, no person shall us e a material for either spray equipment cleaning or cleanup that has an ROC content exceeding 25 grams per liter of material.

On or before July 7, 2008, no person shall use organic solvent for cleanup

unless:

1) An enclosed gun washer or "l ow emission spray gun cleaner" that has been approved in writing by the APCO is properly used for spray equipment cleaning, and

2) The ROC composite pa rtial pressure of organic solvent used for cleanup, including spray equipment cleaning, is less than 45 mm Hg at 20 o C.

5. All ROC containing materials, incl uding, but not limited to surface coatings, cleanup solvents, or surface preparation ma terials shall be stored in closed

containers which are nonabs orbent and do not leak.

6. Coating Compliance Statement: The manufacturer of coatings subject to this rule shall designate on product labe ls or data sheets, the RO C content or the Volatile Organic Compounds (VOC) content of coa tings including coating reducers and catalysts, as supplied. This designati on 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. All letters and numbers used to designate ROC or VOC content on product labels sha ll be visible and legible.

7. Liquid Cleaning Material Compliance Statement: The manufacturer of liquid cleaning materials used in coating operati ons shall designate on product labels or

data sheets:

a. On or before July 7, 2008, the RO C content and ROC Composite Partial Pressure of cleaning materials as supplied.7/08 Rule 74.12: 5 b. After July 7, 2008, the ROC content 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 or VOC c ontent on product labels shall be visible and legible.

8. Prohibition of Specifications: No person shall specify, solicit or require the application of any coating to any meta l part or product, or the use of any equipment cleaning solvent, if such appli cation 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 produc t at any location in Ventura County.

9. Any person wishing to use a coating ha ving an ROC content greater than that specified on his permit to operate shall apply for a permit modification. Such coating shall not have an ROC content exceeding the a pplicable limit specified in

Subsection B.1.

C. Exemptions

1. Subsection B.1 of this rule does not apply to any one coating provided:

a. No complying coatings are available, and

b. Total usage of all non-complying coatings has not exceeded 55 gallons in any calendar year.

Any person claiming this exemption shall demonstrate the lack of available coatings to the APCO on an annual basis.

2. 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.

3. The provisions of this rule, except Subsection B.8, shall not apply to any stationary source that emits less than 200 pounds of ROC in every rolling period

of 12 consecutive calendar months fro m metal parts and products coating operations. Any person claiming this exemption shall maintain monthly records7/08 Rule 74.12: 6 to substantiate this claim. Emissions from aerosol products, cold cleaners, and vapor degreasers shall not be in cluded in this determination.

4. Subsection B.4.a does not apply to any metal parts coating operation where total usage of non-complying substrate surface cleaners does not exceed five gallons per rolling 12-month period. Any person cl aiming this exemption shall maintain monthly operational records to substantiate this claim.

D. Recordkeeping Requirements

1. Any person subject to this rule shall:

a. Maintain a current list of all coatings that provides all information necessary to evaluate compliance, including the following, as applicable:

1) The name and manufacturer of e ach coating and any catalysts and reducers used with each coating

2) Mix ratio of components used in coatings

3) ROC content of co atings, as applied

4) Coating category from Subsection B.1 of each coating used.

b. Maintain records which show 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

2) ROC content in grams per liter of material

3) On or before July 7, 2008, com posite ROC partia l pressure of organic solvent (cleaning materials only).

c. Maintain records of the monthly volume of each complying coating and ROC containing liquid used for equipment clean-up and surface preparation and daily volume of each noncompliant coating used.

d. Any person using an emission control system as a means of complying with this rule shall maintain daily records of key system operating and maintenance procedures which will demonstrate continuous operation and compliance of the emission control device during periods of emission producing activities. Key system opera ting parameters are those necessary to ensure compliance with subsection B.2 such as temperatures, pressures

and flow rates.7/08 Rule 74.12: 7 2. All lists and records shall be maintained for a minimum of two (2) years from the date of each entry and shall be ava ilable to District personnel upon request.

E. Test Methods

1. The reactive organic compounds content of coatings and liquid cleaning materials,

shall be determined usin g EPA Reference Method 24 (40 CFR 60, Appendix A).

2. Transfer efficiency shall be determined in accordance with the South Coast Air Quality Management District method entitled "Spray Equipment Transfer Efficiency Test Procedure for Equipment Users."

3. ROC composite pressure of a solvent shall be calculated using a widely accepted published source such as: Boublik, T., V. Fr ied and E. Hala, "T he Vapor Pressure of Pure Substances," Elsevi er Scientific Publishing Co., New York (1973), Perry's Chemical Engineer's Handbook, McGraw-Hill Book Company, CRC Handbook of Chemistry and Physics, Chemical Rubber Publishing Company (1986-87), and Lange's Handbook of Chemistry, John A. Dean, editor, McGraw-Hill Book Company (1985). The true vapor pressure of a component in a solvent mix may be determined by ASTM Method D2879-86. The ROC co mposite pressure of a solvent mix consisting entirely of ROC may be determined by ASTM Method

D2879-86.

4. Capture efficiency shall be determined according to EPA Guidelines for Determining Capture Efficiency, dated January 9, 1995, and 40 CFR 51, Appendix M, Methods 204-204F as applicable. Control device efficiency shall be determined by 40 CFR 60, Appe ndix A, Methods 18, 25 or 25A.

5. The acid content of pretreatment wash primers and etching fillers shall be determined by ASTM D1613-85.

6. The solids content of etching fillers shall be determined using EPA Reference

Method 24.

7. The metal content of metallic coatings shall be determined by Spectrographic Method 311 in the South Coast Air Qua lity Management District manual, "Laboratory Methods of Analys is for Enforcement Samples."

8. The active and passive solvent losses fro m spray gun cleaning systems shall be determined using South Coast Air Quality Management District's "General Test Method for Determining Solvent Losses fro m Spray Gun Cleaning Systems" dated October 3, 1989. The test solvent for this determination sha ll be any lacquer thinner with a minimum vapor pressure of 105 mm Hg at 20 o C. The minimum test temperature shall be 15 o C.7/08 Rule 74.12: 8 9. High Volume-Low Pressure (HVLP) equipment shall be identified by either test air cap measurements or an inlet pressu re measurement that, when used with specifications published by the manufactur er, establishes that gun is being operated as specified in Subsection G.24.

F. Violations

Failure to comply with any provision of this ru le, including the maintenance of records, is

a violation of this rule.

G. Definitions

1. "Active Solvent Losses": Emissions dur ing all steps of a spray gun equipment cleaning operation, expressed as grams of solvent loss per cleaning cycle.

2. "Aerosol Coating Product": A pressurize d coating product containing pigments or resins that dispenses product ingredie nts by means of a propellant, and is packaged in a disposable can for hand held application, or for use in specialized equipment for ground traffi c/marking applications.

3. "Aircraft or Aerospace Vehicle": A fa bricated part, assembly of parts or completed unit of any aircraft, helicopter, missile or space vehicle.

4. "Air-Dried Coating": Any coating which is not heated above 90 o C (194 o F) for the purpose of curing or drying.

5. "Baked Coating": Any coating which is cured or dried in an oven where the oven air temperature exceeds 90 o C (194 o F).

6. "Camouflage Coating": A coating that functions to conceal equipment from

detection.

7. "Capture Efficiency": The percentage of ROC used, emitted, evolved, or generated by the operation, that are coll ected and directed to an air pollution

control device.

8. "Carbon Adsorber": A device that adso rbs ROC from a gaseous stream onto the

surface of activated carbon.

9. "Catalytic Incinerator": A device that burns ROC 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.7/08 Rule 74.12: 9 10. "Cleanup": The removal of unc ured coating from any surface.

11. "Coating": A material applied to a me tal surface as a film to beautify and/or protect the surface.

12. "Control Device Efficiency": The per centage by weight of ROC entering a control device that is not emitted to the atmosphere.

13. "Electrostatic Application": The chargi ng of atomized paint droplets to cause deposition by electrost atic attraction.

14. "Etching Filler": A coating that contains less than 23 percent solids by weight and at least 1/2 percent acid by weight, and is used instead of a pretreatment wash primer on a metal substrate prior to a primer.

15. "Exempt Organic Compounds": As defined in Rule 2, Definitions, of these rules.

16. "Extreme Performance Coating": Any co ating except a zinc filled primer, a laboratory furniture coating, or a pretreatment coating that is exposed to any of the following conditions:

a. Industrial-grade detergents, clean ers, or abrasive scouring agents.

b. Unprotected shipboard conditions.

c. Frequent or chronic exposure to salt water, corrosives, caustics, acids, or oxidizing chemicals.

d. Other similar or more ha rsh environmental conditi ons as determined in writing by the APCO.

17. "Grams of ROC per liter of coating, less water and exempt organic compounds": The weight of ROC per combined volum e of ROC and coating solids calculated

as follows:

Grams of ROC per Liter of Coating Ws - Ww - Wes Less Water and Less Exempt Organic Compounds = Vm - Vw - Ves

Where: Ws = Weight of volatile compounds (grams) Ww = Weight of water (grams) Wes = Weight of exempt organic compounds (grams) Vm = Volume of material (liters) Vw = Volume of water (liters) Ves = Volume of exempt organic compounds (liters)7/08 Rule 74.12: 10 18. "Grams of ROC per liter of material": The weight of ROC per volume of material

calculated as follows:

Grams of ROC per Liter of Material

= Ws - Ww - Wes

Vm

Where: Ws = Weight of volatile compounds (grams) Ww = Weight of water (grams) Wes = Weight of exempt organic compounds (grams) Vm = Volume of material (liters)

19. "Gun Washer": Electrically or pneumatica lly operated system that is designed to clean spray application equipment while enclosed. A gun washer may also be considered a gun cleaning system that consists of spraying solvent into an enclosed container using a snug fitting.

20. "Hand Application Methods": The app lication of coatings by nonmechanical hand-held equipment including but not limited to paint brushes, hand rollers, caulking guns, trowels, spatulas, syringe daubers, rags and sponges.

21. "Heat Resistant Coating": Any applied coa ting that, after curing, must withstand a temperature of at least 204 o C (400 o F) during normal use.

22. "High Gloss Coating (Multi-Component )": Any multi-component coating which

when tested in accordance with ASTM Te st Method D523-89 has a reflectance of 85 percent or more on a 60 degree meter.

23. "High Performance Architectural Coatin g": Any coating used to protect

architectural subsections and which is re quired to meet the sp ecifications of the

Architectural Aluminum Manufacturer Association' s publication number AAMA

605.2-1992.

24. "High Temperature Coating": Any coatin g that after curing, must withstand a temperature of at least 538 o C (1000 o F) during normal use.

25. "High Volume-Low Pressure Applicati on (HVLP)": Equipment used to apply coatings by means of a spray gun design ed to be operated and operated between 0.1 and 10 pounds per square inch gauge (psi g) air pressure measured dynamically at the center of the air cap and at the air horns.

26. "Leak": The dripping of three or mo re drops per minute of ROC containing liquids.

27. "Low Emissions Spray Gun Cleaner": Any properly used spray equipment cleanup device which has passive solvent losses of no more than 0.6 grams per7/08 Rule 74.12: 11 hour and has active solvent losses of no mo re than 15 grams per operating cycle as determined by the test method in Subsection E.8.

28. "Metallic Coating": Any coating, excep t zinc filled primer, which contains 5 grams of metal particles per liter of coating, as applied, where such particles are

visible in the dried film.

29. "Metal Part or Product": Any component or complete unit fabr icated from metal, not including stationary structures or th eir appurtenances, mari ne vessel exteriors, aerospace vehicles and components, and mo tor vehicles and mobile equipment.

30. "Mold-Seal Coating": The initial coating applied to a new or repaired mold to prevent products from sticking to the mold.

31. "Multi-Component Coating": A coating re quiring the addition of one or more separate components, commonly known as catalyst or hardener, prior to application to form an acceptable dry film.

32. "One-Component Coating": Any coating th at is ready for application as it comes out of its container to form an accepta ble dry film. A thinner or reducer, necessary to reduce the viscosity, is not considered a component.

33. "Operation": The coating, surface prep aration, and cleaning of metal parts or products and any associated activities incl uding but not limited to the cleaning of coating application equipment.

34. "Pan Backing Coating": Any coating app lied to the surface of pots, pans, or other cooking utensils that are exposed directly to a flame or othe r heating elements.

35. "Passive Solvent Losses:" Emissions resulting from natura l vaporization of solvent from spray gun cleaning equipment not being used in a cleaning cycle.

36. "Powder Coating": Any coating applied as fine particle solid s with less than 4 percent by weight ROC or other liquid carriers.

37. "Pretreatment Wash Primer": Any coa ting which contains at least one half percent acid by weight to provide surf ace etching, corrosion resistance, adhesion, and ease of stripping when applied to a metal surface.

38. "Reactive Organic Compounds": As defined in Rule 2, Definitions, of these rules.

39. ROC Composite Par tial Pressure": The sum of the partial pressures of the compounds defined as ROCs. ROC composite partial pressure is calculated as

follows:7/08 Rule 74.12: 12 

## ( ) ( ) ( )

PP W VP

MW

W

MW W

MW W

MW c i i

i i n

w

w e

e e n i

i i n =       +       +       =

= = 

# ∑ ∑ ∑ 1

1 1

Where:

W i = Weight of the "i"th ROC compound, in grams

W w = Weight of water, in grams

W e = Weight of the "e"th exempt organic compound, in grams

MW i = Molecular weight of the "i"th ROC compound, in g/(g-mole)

MW w = Molecular weight of water, in g/(g-mole)

MW e = Molecular weight of the "e"t h exempt compound, in g/(g-mole)

PP c = ROC composite partial pre ssure at 20 C, in mm Hg

VP i = Vapor pressure of the "i"th ROC compound at 20 C, in mm Hg.

40. "ROC Content": For coatings, ROC ( VOC) content means the grams of ROC per liter of coating, less wa ter and less exempt organic compounds. For liquid cleaning materials and other ROC containing materials, ROC content means the grams of ROC per liter of material.

41. "Silicone Release Coating": Any coa ting which contains silicone resin and functions to prevent food from sticking to metal surfaces such as baking pans.

42. "Solar Absorbent Coating": Any coa ting which has as its prime purpose the absorption of solar radiation.

43. "Substrate Surface Cleaning": Cleaning of a substrate to remove dirt, oils, and

other contaminants. Substrate surface cl eaning is typically done prior to the application of surface coatings, adhesi ve bonding materials, or sealants.

44. "Thermal Incinerator": A device that bur ns ROC in air by direct application of heat. Thermal incinerators are usually equipped with burne rs, refractory lined chambers, heat recovery equipm ent, and process controllers.

45. "Transfer Efficiency": The ratio of the weight of coating solids adhering to the part being coated to the weight of coa ting solids used in the application process expressed as a percentage.

46. "Vacuum Metalizing Coating": Any underc oat applied to a substrate prior to application of a metal film, or an overcoat applied directly to the metal film.

47. "Volatile Organic Compounds (VOC)": Reactive organic co mpounds (ROC).

48. "Zinc Filled Primer": Any coating which ha s an elemental zinc content of not less than 240 grams/liter (2.0 pounds per gallon) as applied.