Air Pollution Control Board

San Diego County Air Pollution Control 

District

AGENDA ITEM

Governing Body

GREG COX

First District

DIANNE JACOB

Second District

PAM SLATER-PRICE

Third District

RON ROBERTS

Fourth District

BILL HORN

Fifth District

Documentum Version 3.1

DATE: November 9, 2011 AP02

TO: Air Pollution Control Board

SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO 

RULE 67.4 – METAL CONTAINER, METAL CLOSURE, AND METAL 

COIL COATING OPERATIONS (DISTRICT: All)

SUMMARY: 

Overview

The Air Pollution Control Board is requesting to adopt proposed amendments to 

Rule 67.4, limiting emissions of volatile organic compounds from the application of 

coatings to metal containers, closures, and coils and related cleaning activities. Volatile 

organic compounds emitted into the atmosphere contribute to the formation of ozone, 

which at elevated levels can impact public health. Despite substantial air quality 

improvement over the past two decades, San Diego County does not yet attain state and 

federal air quality standards for ozone. 

The amendments, if adopted, will reduce the allowable amount of volatile organic 

compounds in cleaning materials used in affected coating operations, consistent with 

existing requirements of several air districts in California. The amendments help fulfill 

federal and state requirements in ozone nonattainment areas to update rules as 

necessary to reflect the current state of air pollution control technology.

Recommendation(s)

AIR POLLUTION CONTROL OFFICER

1. Find that the adoption of amended Rule 67.4 is categorically exempt from the 

provisions of the California Environmental Quality Act pursuant to California Code 

of Regulations, Title 14, Section 15308, as an action taken to assure the protection 

of the environment, where the regulatory process involves procedures for protection 

of the environment, and pursuant to California Code of Regulations Title 14, 

Section 15061(b)(3), since it can be seen with certainty that there is no possibility 

that the activity in question may have a significant effect on the environment.

2. Adopt the resolution entitled Resolution Amending Rule 67.4 – Metal Container, 

Metal Closure and Metal Coil Coating Operations into Regulation IV of the Rules 

and Regulations of the San Diego County Air Pollution Control District.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENT TO RULE 

67.4 – METAL CONTAINER, METAL CLOSURE, AND METAL COIL 

COATING OPERATIONS (District: All)

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Fiscal Impact

The proposed amendments to Rule 67.4 will not have a fiscal impact on the Air 

Pollution Control District. The rule will be implemented and enforced with existing 

Air Pollution Control District staff.

Business Impact Statement

Adopting the proposed amendments to Rule 67.4 will not adversely impact the business 

community. The companies subject to the rule already use cleaning materials that 

comply with the proposed amendments.

Advisory Board Statement

At its meeting on April 14, 2011, with a quorum present, the Air Pollution Control 

District Advisory Committee supported the Air Pollution Control District’s 

recommendations.

BACKGROUND:

San Diego County does not currently meet the National and State Ambient Air Quality Standards 

for ozone and therefore is classified as an ozone nonattainment area. Both federal and state laws 

require the San Diego County Air Pollution Control District (District) to implement rules that 

regulate emissions of ozone precursors – volatile organic compounds (VOCs) and oxides of 

nitrogen.

Existing Rule 67.4 regulates VOC emissions from metal container, metal closure, and metal coil 

coating operations. The rule was adopted in 1979 and last revised in 1996. The major goal in 

amending Rule 67.4 is to make the VOC emission limits consistent with those in other districts 

and to reflect the greater level of control actually achieved by the two companies subject to the 

rule, in compliance with federal and state requirements. Following its adoption, proposed 

amended Rule 67.4 will be submitted to the U.S. Environmental Protection Agency to replace 

existing Rule 67.4 in the State Implementation Plan.

The proposed amendments reduce the VOC content limit for cleaning materials to 25 grams per 

liter unless specified cleaning and emission control equipment is used; include a new section to 

require the use of high transfer efficiency coating application equipment; clarify record keeping 

requirements; and update definitions of terms used in the rule. In addition, the proposed 

amendments update the test methods for determining the content of VOC and exempt 

compounds in coatings and cleaning materials and the overall efficiency of emission control 

systems. 

There are two facilities subject to Rule 67.4 in San Diego County. One facility currently uses 

water-based coatings with a very low VOC content and water as a cleaning material, and has 

negligible VOC emissions. The other facility currently uses low VOC content coatings and 

acetone (an exempt compound) as a cleaning agent. The total VOC emissions from this facility 

are about 3.6 tons/year. Both companies already comply with all proposed rule amendments.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENT TO RULE 

67.4 – METAL CONTAINER, METAL CLOSURE, AND METAL COIL 

COATING OPERATIONS (District: All)

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Socioeconomic Impact Assessment

Section 40728.5 of the State Health and Safety Code requires the District to assess the 

socioeconomic impacts when adopting, amending, or repealing a rule that will significantly 

affect air quality or emission limitations. While the amendments to Rule 67.4 require using 

cleaning materials with a lower VOC content for coating operations, the proposed emission 

limits are already being achieved by the facilities subject to this amended rule. The cleaning 

materials used by these facilities are now in compliance. Accordingly, this requirement will not 

adversely affect facilities subject to the rule, and the adoption of the amendments to Rule 67.4 

will not significantly affect air quality or emission limitations and does not require a 

Socioeconomic Impact Assessment.

Environmental Statement

The adoption of amended Rule 67.4 is exempt from the California Environmental Quality Act 

(CEQA) pursuant to California Code of Regulations, Title 14, Section 15308, as an action taken 

to assure the protection of the environment, where the regulatory process involves procedures for 

protection of the environment. In this case, this action is being taken in response to federal and 

state requirements to reduce emissions of VOCs in order to achieve ambient air quality 

standards. Additionally, this action is also exempt pursuant to California Code of Regulations 

Title 14, Section 15061(b)(3), since it can be seen with certainty that there is no possibility that 

the activity in question may have a significant effect on the environment. The two facilities 

subject to the amended rule are already operating in compliance with the amended requirements, 

and will not be required to change their operations.

Linkage to the County of San Diego Strategic Plan

The County's five-year strategic plan includes an Environment Initiative to ensure environmental 

preservation and enhance quality of life. The proposed amendments to Rule 67.4 will codify the 

use of materials with a very low content of VOCs that contribute to ozone formation, without 

negatively impacting the local business community. The rule balances air quality preservation, 

public health protection, and economic development needs.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENT TO RULE 

67.4 – METAL CONTAINER, METAL CLOSURE, AND METAL COIL 

COATING OPERATIONS (District: All)

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ATTACHMENTS

Attachment A – Resolution Amending Rule 67.4 –Metal Container, Metal Closure and Metal 

Coil Coating Operations of Regulation IV of the Rules and Regulations of the 

San Diego County Air Pollution Control District

Attachment B – Comparative Analysis

Attachment C – Incremental Cost Effectiveness Analysis

Attachment D – Workshop Report

Attachment E – Change Copy
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENT TO RULE 

67.4 – METAL CONTAINER, METAL CLOSURE, AND METAL COIL 

COATING OPERATIONS (District: All)

AGENDA ITEM INFORMATION SHEET

REQUIRES FOUR VOTES: [] Yes [X] No

WRITTEN DISCLOSURE PER COUNTY CHARTER SECTION 1000.1 REQUIRED

[] Yes [X] No

PREVIOUS RELEVANT BOARD ACTIONS:

May 15, 1996 (APCB #2), Amendment of Rule 67.4 – Metal Container, Metal Closure and 

Metal Coil Coating Operations.

BOARD POLICIES APPLICABLE:

N/A

BOARD POLICY STATEMENTS:

N/A

MANDATORY COMPLIANCE:

N/A

ORACLE AWARD NUMBER(S) AND CONTRACT AND/OR REQUISITION 

NUMBER(S): N/A

ORIGINATING DEPARTMENT: Air Pollution Control District

OTHER CONCURRENCE(S): N/A

CONTACT PERSON(S):

ROBERT J. KARD

Name Name

(858) 586-2700

Phone Phone

(858) 586-2701

Fax Fax

O-176

Mail Station Mail Station

Robert.Kard@sdcounty.ca.gov

E-mail E-mail