UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Santa Barbara County Air Pollution Control District, 

Rule 330, 

Surface Coating of Metal Parts and Products

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

September 2013
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RULE IDENTIFICATION

Agency: Santa Barbara County Air Pollution Control District 

(SBCAPCD)

SIP-Approved Rule: Rule 330 – Surface Coating of Metal Parts and 

Products 

Adopted – January 20, 2000

Submitted – March 28, 2001

Approved – June 8, 2001 (65 FR 36349)

Subject of this TSD: Rule 330 - Surface Coating of Metal Parts and Products 

Amended – June 21, 2012

Submitted – September 21, 2012

RULE SUMMARY - Rule 330 establishes reactive organic content (ROC) limits and 

workplace standards for industrial sites engaged in the use, application and 

solicitation of coating and solvents used for metal parts and products, including the 

cleanup of equipment, and the storage and disposal of waste coating and solvent 

materials associated with these sites. It also describes related recordkeeping, 

reporting, and monitoring requirements. 

Changes from the approved SIP rule include the following:

1. Section A, Applicability: This section was expanded to include “...any person 

who manufactures any metal part or metal product coating for use within the 

District.” The applicability to “any person who specifies the use of any metal 

part coating..” was increased to “any person who solicits...” and the solvents 

applicable to metal parts or products coating was added to the applicable 

products. 

2. Section B, Exemptions: Several exemptions have been added or amended 

which are included in analogous rules for South Coast Air Quality 
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Management District (SCAQMD), San Joaquin Valley Unified Air Pollution 

Control District (SJVUAPCD) and Bay Area Air Quality Management District 

(BAAQMD) with the exception of subsection B.11 d, e and g which exempts 

the solvent cleaning of various specialized procedures from the 25 

grams/liter VOC limit indicated in Section J for cleaning of parts assemblies 

or subassemblies exposed to strong oxidizers or reducers, cleaning of 

transparencies or glass substrates and cleaning or stripping of coating 

overspray from personal protective equipment. These exemptions are deemed 

necessary for safe operating procedures. Section 12 was also added to allow 

the use of low-VOC (less than 20 grams/liter) coatings.

3. Several new definitions were added in Section C. All definitions are either 

defined in the Control Techniques Guideline (CTG)1or in the district’s SIPapproved Rule 102, Definitions. The only exception to this is the definition for 

High Volume Low Pressure Spraying which was deleted in this revision 

although it remains an acceptable application method. 

4. The ROC limits in Section D are similar to or lower than those in the CTG. 

However, this rule does not address the specific categories indicated in the 

CTG. Instead, only limits for Air-dried and Baked Non-powder Coatings, Nonpowder Air-dried Extreme Performance and Electric-insulating Coatings and 

Powder Coatings are specified. These five categories are consistent with the 

CTG’s General One Component, General Two Component Air-dried and 

Baked Coating VOC limits and Extreme Performance and Electric Insulation

Air-dried Coating VOC limits. The CTG does not have a limit for powder 

coating since “...no VOCs are released during the application operation, and 

volatile emissions from the curing operation, if any, are generally much less 

than the volatile emissions from liquid coating systems.” These limit values 

are equal or less than those of SJVUAPCD Rule 4603 Surface Coating of 

Metal Parts and Products, Plastic Parts and Products and Pleasure Crafts, 

 

1. CTG for Miscellaneous Metal and Plastic Parts Coatings – EPA-453/R-08-003, September 2008
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BAAQMD Rule 8-19, Surface Preparation and Coating of Miscellaneous Metal 

Parts and Products and SCAQMD Rule 1107, Coating of Metal Parts and 

Products. One exception is the SCAQMD limit for one-component general airdried coating which is 275 grams/liter, slightly lower than the 340 

grams/liter of this rule. In addition, the overall efficiency specified in this 

section is 85.5% which is slightly lower than the 90% recommended in the 

CTG.

5. Section E, Application Equipment had only minor changes. We note that High 

volume, low pressure spraying has been retained in subsection 4, but this 

method has been deleted from the definitions in section C. Additionally, the

additions to subsection 8 now allow other application methods if they are 

approved by the Control Officer, California Air Resources Board (CARB) and 

the EPA. The required transfer efficiency for alternate applications was 

revised from “at least 65%” to “equivalent to or greater than 65%...”

6. Section F, General Operating, which had been entitled “Closed Container”, is 

basically a housekeeping section. Several subsections were added to include 

the selection of application equipment, disposal of waste materials, the use of 

devices to reduce coating or solvent evaporation and basic handling and 

storage of coatings and solvent. It is now comparable, in detail, to the Work 

Practices section of SJVUAPCD’s Rule 4603.

7. Section G, Requirements – Manufacturer Labeling, had only minor, clarifying 

changes. The section was renamed from “Requirements – Labeling” to 

“Requirements – Manufacturer Labeling”. 

8. Section H, Recordkeeping, was expanded to include more detail for stationary 

source materials, records of disposal methods, usage records for compliant, 

non-compliant materials, including those claiming exemptions and those 

operations using emission control equipment. The recordkeeping in general is 

now applicable to “any owner or operator of any stationary source comprised 

of more than one facility on a facility basis.” 
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9. Section I was renamed Compliance Provisions and Test Methods and is 

divided and greatly expanded according to test results, such as: reactive 

organic compound content, capture and control device efficiency, capture 

efficiency for toxic air contaminant emissions and emission control systems 

VOC emissions rather than by rule section as was the previous arrangement. 

Several more test methods have been included.

10. New sections for solvent cleaning (section J), a compliance schedule (section 

K), reporting criteria for permitted facilities (section L) and requirements for 

solvent cleaning machines (section M) were added to rule 330.

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

the submitted rule:

1. Enforceability - CAA section 110(a) (2) (A) requires that regulations 

submitted to EPA for approval into a SIP must be clear and legally 

enforceable.

2. Rule Stringency – CAA section 172(c)(1) requires nonattainment areas to 

implement all reasonably available control measures (RACM), including such 

reductions in emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonably available control 

technology (RACT), as expeditiously as practicable. In addition, under CAA 

section 182(b)(2), ozone nonattainment areas classified as moderate or 

above must implement RACT for all VOC sources covered by a CTG 

document and all other major sources of VOCs. The SBCAPCD regulates an 

area that is classified as maintenance for the 1-hour ozone standard and is in 

attainment for all criteria pollutants, thus, submitted Rule 330 does not have to 

fulfill RACT requirements.40 C.F.R. § 81.305 (2010). EPA’s CTGs titled

Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts 

Coatings (EPA-453/R-08-003, September 2008) herein referred to as the 
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“Metal Parts Coating CTG”, Control Techniques Guidelines for Large 

Appliance Coatings (EPA-453/R-07-004, September 2007), Control

Techniques Guidelines for Metal Furniture Coatings (EPA-453/R-07-005, 

September 2007) and Control Techniques Guidelines: Industrial Cleaning

Solvents (EPA-450/R-06-001, September 2006) cover many of the sources 

regulated under Rule 330.

3. SIP Relaxation - CAA section 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. In addition, CAA section 193 prohibits the 

modification of any SIP-approved control requirement in effect before 

November 15, 1990, in a nonattainment area.

In applying these criteria to the submitted rule, we referred to the following guidance 

and policy documents:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and 

Deviations (the "Blue Book"), US EPA, OAQPS (May 25, 1988).

 Guidance Document for Correcting Common VOC and Other Rule 

Deficiencies, EPA Region IX (August 21, 2001, the “Little Bluebook”).

 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).

 EPA’s Solvent Metal Cleaning CTG.

In addition, we reviewed other state and local rules for this source category.

RULE EVALUATION

1. Enforceability – The recordkeeping requirements for coatings and control 

system parameters, test methods and other requirements generally ensure that 

the submitted rule can be enforced. They include records of usage of 

compliant and noncompliant materials, purchase records, records of key 
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operating parameters and records for those claiming an exempt status. 

Therefore, we propose to determine that submitted Rule 330 is sufficiently 

clear and enforceable.

2. Stringency – The Metal Parts Coating CTG contains EPA’s most recent 

identification of national presumptive RACT for this industry. Since SBCAPCD 

is in attainment, it is not required to meet RACT. Nevertheless, the VOC 

limits in amended Rule 330 are generally as, or more, stringent than the 

VOC limits in this CTG, and we are not aware of significantly more stringent 

requirements in other analogous regulations. 

Rule 330 also identifies VOC content limits for solvents that are, for the most 

part, addressed by the Aerospace CTG. Section D.3 of the rule allows, as an 

alternative to compliance with these limits, the use of an add-on control 

system with an overall efficiency of at least 85.5% exceeding the 81% of the 

Aerospace CTG. In addition, compliance through use of such a control 

system must not result in emissions greater than the VOC emissions that 

would have resulted if materials in compliance with the applicable VOC limits 

had been used. 

3. SIP Relaxation - In addition, we believe the submitted rule is more stringent 

than the version previously approved into the SIP, so the submitted rule does 

not relax the SIP and complies with CAA §110(l) and §193.

RULE DEFICIENCIES – We have identified no deficiencies in submitted Rule 330

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:

1. The definition for High Volume Low Pressure Spraying in Section C, 

Definitions, was removed in this rule’s current revision. Since this remains an 
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accepted application method in subsection E-4, we recommend reinstating 

this definition.

2. The coating categories indicated in subsection D-1 are very general and may 

be problematic if other categories are introduced into the district. In fact, 

although the limits are analogous to the general categories of the CTG for 

Miscellaneous Metal and Plastic Parts Coatings, the air-dried general one and 

multi-component categories in the CTGs for both the CTG for Large 

Appliance Coatings and the CTG for Metal Furniture Coatings have a lower 

limit of 275 grams/liter. We recommend that categories similar to that of the 

CTG for Miscellaneous Metal and Plastic Parts Coatings be included and that 

consideration be given to lowering the limit for the air-dried general coating 

category. 

3. In subsection D-4-a, the overall efficiency of the total (control) system is 

required to be at least 85.5%. We recommend a slightly higher efficiency of 

90% suggested in the CTG for Miscellaneous Metal and Plastic Parts 

Coating.

EPA ACTION - EPA staff recommends a full approval of Rule 330 pursuant to CAA 

§110(k) (4) and §301(a). 

ADDITIONAL REFERENCES –

1. SBCAPCD Rule 330 – Surface Coating of Metal Parts and Products 

submitted September 21, 2012

2. SBCAPCD Rule 330 – Surface Coating of Metal Parts and Products, as 

approved into the SIP on January 8, 2001. 

3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts 

Coatings,” EPA-453/R-08-003, September 2008. 

http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200809_voc_epa

453_r-08-003_misc_metal_plasticparts_coating.pdf
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4. “Control Techniques Guidelines for Large Appliance Coatings,” EPA-453/R07-004, September 2007. 

http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200709_voc_epa

453_r-07-004_lg_appliance_coating.pdf

5. “Control Techniques Guidelines for Metal Furniture Coatings,” EPA-453/R07-005, September 2007. 

http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200709_voc_epa

453_r-07-005_metal_furniture_coating.pdf

6. “Control Techniques Guidelines: Industrial Cleaning Solvents,” EPA-453/R06-001, September 2006.

http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200609_voc_epa

453_r-06-001_ind_cleaning_solvents.pdf

7. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

8. “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.