SAN DIEGO AIR POLLUTION CONTROL DISTRICT

Regulation I V

- 1

- Rule 67.4 RULE 67.4. METAL CONTAINER, METAL CLOSURE AND METAL COIL

COATING OPERATIONS (Effective 5/9/79: Rev. Adopted & Effective

5/15/96 ; Rev. Adopted and Effective 11/09/11 )

(a) APPLICABILITY

(1) This rule applies to all metal container, metal closure and me tal coil coating operations in which volatile organic compounds (VOCs) are employed

.

(2) Operations subject to this rule shall not be subject to Rule 66 .1 or 67.3.

(b) RESERVED

(c) DEFINITIONS

For the purpose of this rule, the following definitions sha ll apply:

(1) "Cleaning Material" means a VOC containing material used for cleaning hands, tools, application equipment and work area.

(2) "Closure" means any metal component which is used to close or seal a container.

(3) "Coating Line" means an ope ration or process for applying, drying or oven baking and/or curing surface coatings, together with associated equipment including a coating applicator, flash

- off area and oven.

(4) "Coil" means any flat metal sheets or strips that have been formed into rolls or

in concentric rings for further industrial or commercial use.

(5) "Container" means any can, pail or drum.

(6) "Drum" means any manufactured or reconditioned cylindrical metal container

that has a capacity larger than 12 gallons but smaller th an 110 gallons.

(7) "End" means a part of a container which is used for its closure after the container is filled with a product.

(8) "End Sealing Compound" means a compound which is coated onto a container closure and which functions as a gasket whe n the closure is assembled onto the container.

(9) "Exempt Compound" means the same as defined in Rule 2.

(10) "Exterior Base Coating" means a coating applied to the exterior of a container, body, closure or flat sheet to provide a protection to the me tal or to provide background for any lithographic operation.

(11) "Exterior Body Spray" means a coating sprayed on the exterior of the container body to provide a decorative or protective finish.Regulation I V

- 2

- Rule 67.4 (12) "Food/Beverage Container" means a metal container i n which food or beverages intended for human consumption are packaged.

(13) “High

- Volume Low

- Pressure (HVLP) Spray” means a coating application method using a spray applicator and pressurized air which is designed to be operated and which is operated at an atomizing pressure between 0.1 and 10.0 psig, measured dynamically at the center of the applicator’s air cap and at the applicator’s air horns.

( 14 ) "Interior Base Coating" means a coating applied to the interior of a container body or end or flat she et to provide a protective lining between the product and the

container.

( 15 ) "Interior Body Spray" means a coating sprayed on the interior of the container to provide a protective film between the product and the container.

( 16 ) "Letterpress Coating" means an acrylate

- based topcoat which is used for coating letterpress printing plates during the manufacture of such plates.

( 17 ) "Lid" means a reusable closure.

( 18 ) "Metal Container, Metal Closure, and Metal Coil Coating" means any coating contain ing VOCs applied by spray, roller or other means to the inside and/or outside of metal containers, drums, pails, lids, closures or to the surface of flat sheets, rolls,

or coil for further industrial or commercial use.

( 19 ) "Overvarnish" means a coating applied directly over a design coating to reduce the coefficient of friction, to provide gloss and to protect the finish against abrasion

and corrosion.

( 20 ) "Pail" means any manufactured or reconditioned cylindrical metal container with a capacity betwe en one and 12 gallon s, and constructed of 29 gauge material or heavier

.

( 21 ) "Pet Food Container" means a metal container in which food for animal (non

human) consumption is packaged.

(22 ) "Stationary Source" means the same as defined in Rule 2.

( 23 ) "Three

- Piece Container Side

- Seam Spray" means a coating sprayed on the exterior and/or interior of a welded, cemented or soldered seam to protect the exposed

metal.

( 24 ) "Two

- Piece Container Exterior End Spray" means a coating sprayed on the

exterior bo ttom end of a container to provide protection to the metal.

( 25 ) "Volatile Organic Compound (VOC)" means the same as defined in Rule 2.Regulation I V

- 3

- Rule 67.4 ( 26 ) "VOC Content per Volume of Coatings, Less Water and Exempt Com

pounds" means the same as defined in Rule 2.

( 27 ) "VOC Content per Volume of Cleaning Material" means the same as

defined in Rule 2

, “ VOC C ontent per Volume of M aterial ”

.

(d) STANDARDS

(1) VOC Limits

Except as provided for in Section (e), a person shall not use or apply coatings on any coating l ine of the type designated below which contains VOCs in excess of the following limits at the point of application:

(i)

Metal Container or Closure Coating Lines Grams of VOC per liter of coating (less water

and exempt compounds) Sheet base coat (exterio r and interior) and

overvarnish 180

Two

- piece contain e r exterior base coat and

overvarnish , and end spray 250

Container exterior body spray and exterior closure

spray 250

Three

- piece container side seam spray 660 End sealing compound: Food/Beverage Co ntainer:

Pet Food Container

Non

- Food Container 20

20

20 Container interior body spray:

Two

- piece container

Three

- piece container 420

310 Reconditioned drums, pails and lids: Exterior spray Interior spray 420

510 New drums, pails and lids: Exterior sp ray Interior spray 340

420

(ii)

Coil Coating Line Grams of VOC per liter of coating (less water

and exempt compounds) (A) Letterpress coatings 200 (B) Other coil coatings 200Regulation I V

- 4

- Rule 67.4 (2) Coating Application Equipment

A person shall conduct coating op erations subject to this rule by using only the following coating application methods:

(i) Electrostatic spray application; or

(ii) Flow coat application; or

(iii) Dip coat application; or

(iv) Roll coat; or

(v) Hand application methods; or

(vi ) High

- volume low

- pressure (HVLP) spray. Facilities using an HVLP spray gun shall have available on site pressure gauges in proper operating condition to measure the air cap pressure or have available manufacturer’s technical information regarding the cor relation between the handle air inlet pressure and the air cap pressure. If the correlation option is used to demonstrate compliance, a handle air inlet pressure gauge will be required on site in proper operating condition to measure

the handle air inlet pressure; or

(vii) Other coating application methods that are demonstrated to have transfer efficiency at least equal to one of the above application methods, and which are used in such a manner that the operating parameters under which they were demonstr ated to achieve such transfer efficiency are permanent features of the method. Such coating application methods shall be approved in writing by the Air Pollution Control Officer prior to use.

( 3 ) Cleaning of Coating Application Equipment

A person sha ll not use VOC containing materials for the cleaning of coating application equipment used in operations subject to this rule unless :

(i) The VOC content of cleaning material is 25 grams or less per liter of material; or

( i i ) The cleaning material is flushed or rinsed through the application equip

ment in a contained manner that will minimize evaporation into the atmosphere; or

( iii ) The application equipment or equipment parts are cleaned in a container which is open only when being accessed for ad ding, cleaning, or removing application equipment or when cleaning solvent is being added, provided the cleaned equipment or equipment parts are drained to the container until dripping ceases; or

( iv ) A system is used that totally encloses the component parts being cleaned during the washing, rinsing, and draining processes

.Regulation I V

- 5

- Rule 67.4

(e) CONTROL EQUIPMENT

(1) In lieu of complying with the provisions of Subsection (d)(1) and (d)(3) a person may use an air pollution control system which:

(i) has been installed i n accordance with an Authority to Construct; and

(ii) includes an emission collection system which captures and transports organic gaseous emissions to an air pollution control device; and

(iii) has a combined VOC emissions capture and control device e fficiency of at least 85 percent by weight.

(2) A person subject to the requirements of this section shall submit to the Air Pollution Control Officer for approval an Operation and Maintenance (O&M) plan for the proposed emission control device and emissi on collection system. Such plan shall:

(i) identify all key system operating parameters. Key system operating parameters are those necessary to ensure compliance with Subsection (e)(1)(iii) such as temperature, pressure, and/or flow rate, and

(ii) in clude proposed inspection schedules, anticipated ongoing maintenance, and proposed recordkeeping practices regarding the key system operating parameters.

(3) The Operation and Maintenance plan must be submitted to the Air Pollution

Control Officer and rec eive approval prior to operation of the air pollution control equipment. A person subject to the requirements of this section shall implement the plan on approval of the Air Pollution Control Officer.

(f) RECORD KEEPING

Any person subject to the require ments of this rule shall maintain records in accordance with the following:

(1) Coating and Cleaning Materials

Any person subject to the requirements of Subsections (d)(1) and/or (d)(3) shall:

(i) Maintain a current list of coatings and cleaning materials in use. This list shall provide all the data necessary to evaluate compliance, including, but not limited

to: (A) Material name, manufacturer and manufacturer identification;

(B) Type and applicable coating category of each coating used as specified in Subsection (d)(1)(i) and (d)(1)(ii);

(C) VOC content, less water and exempt compounds, of coatings, as applied and VOC content of cleaning materials, as used.Regulation I V

- 6

- Rule 67.4 (ii) Maintain monthly or daily records showing the amount of each coating, the applicable coating category and cleaning material used.

( 2 ) A ny person using control equipment pursuant to Section (e) of this rule shall:

(i) F or all materials not in compliance with Subsection (d)(1) of this rule, maintain daily records of the amount of each material used ; and

(ii) M aintain daily records sufficient to document continuous compliance with Subsection (e)(1)(iii), including records of key system operating parameters as approved in the Operation and Maint enance plan.

All records shall be retained on site for at least three years, and shall be made available to the District upon request.

(g) TEST METHODS

When more than one test method or set of test methods are specified in this Section, a

violation of a ny requirement of this rule established by any one of the specified test methods or

set of test methods shall constitute a violation of the rule.

(1) The VOC content of coatings containing more than 50 grams of VOC per liter

and subject to Subsections (d )(1)(i) and (d)(1)(ii)(B) shall be determined by the Environmental Protection Agency (EPA) Reference Method 24 (Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface

Coatin gs, 40 CFR Part 60, Appendix A)

, dated 9/11/1995

, or by the South Coast Air Quality Management District (SCAQMD) Method 304 (Determination of Volatile Organic Compounds in Various Materials)

, dated February 1, 1996

.

(2) Measurements of VOC content of coatings subject to Subsection (d)(1)(ii)(A) of this rule shall be conducted in accordance with San Diego Air Pollution Con trol District's Method 24D for Determination of Density, Total Volatile Matter Content, and Weight Solids of Surface Coatings Containing Photosensitive Reactive Di luents

, dated July 1993

.

(3) The VOC content of coatings containing 50 grams of VOC per liter or less, or cleaning materials shall be determined by the SCAQMD Method 313

- 91 (Determination of Volatile Organic Compounds by Gas Ch romatography/Mass Spectromet ry)

, dated July

1991

, or the SCAQMD Method 308

- 91 (Quantit ation of Compounds by Gas Chromatography)

, dated February 1993

.

(4) The content of methyl acetate, acetone and parachlorobenzotrifluoride

shall be determined in accordance with the ASTM Test Me thod D6133

- 02 (2008) (Standard Test Method for Acetone, p

- Chlorobenzotrifluoride, Methyl Acetate or t

- Butyl Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and Raw Materials by Direct Injection Into a Gas Chromatograph )

.Regulation I V

- 7

- Rule 67.4 (5) Meas urements of exempt compound content, other than determined in accordance with Subsection (g)(4), shall be conducted in accordance with the SCAQMD

Test Method 303

- 91 (Determination of Exempt Compounds)

, dated August 1996

.

(6) Measurements of transfer effic iency pursuant to Subsection (d)(2)(vii) of this

rule shall be conducted in accordance with the SCAQMD "Spray Equipment Transfer Efficiency Test Procedure for Equipment User" approved by EPA on May 24, 1989

. The equivalency of coating application equipmen t pursuant to Subsection (d)(2)(vii) shall be determined by the SCAQMD “ Guidelines for Demonstrating Equivalency with District Approved Transfer Efficient Spray Guns”

, dated September 26, 2002

.

(7) The overall control efficiency of air pollution control equipment operated pursuant to Subsection (e)(1)(iii) shall be determined by multiplying the capture efficiency of the emission collection system by the control efficiency of the air pollution control device. The control efficiency of the air pollution co ntrol device shall be determined using EPA Test Methods 25A and/or 18 (40 CFR Part 60, Appendix A) and in accordance with a protocol approved by the Air Pollution Control Officer. Capture efficiency of an emission collection system pursuant to Subsection (e)(1)(ii) shall be determined according to EPA

Test Method s 204 and 204A through 204 F (51 CFR Appendix M) , as applicable, and technical document, “Guidelines for Determining Capture Efficiency,” dated January 9, 1995. Subsequent to the initial complianc e demonstration period, appropriate key system operating parameters as approved by the Air Pollution Control Officer may be used as indicators of the performance of the emission control system.

(8) Other test methods which are determined to be equivalent to the test methods specified in this rule and approved, in writing, by the Air Pollution Control Officer, California Air Resources Board, and EPA may be used in place of the test methods specified in this rule.