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 74.12

, Surface Coating of Metal Parts and Products

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Dec ember, 20102

Agency: Ventura County Air Pollution Control District ( VCAPC D)

Sip Approved Rule: Rule 74.12

- Surface Coating of Metal Parts and

Products Adopted

– November 11, 2003

Submitted

– April 26, 2005 EPA Approved

– October 25, 2005 (70FR61561)

Subject of this TSD: Rule 74.12

- Surface Coating of Metal Parts and

Products

Amended

– July 7 , 2008

Submitted

– January 10

, 2010

RULE SUMMARY

- VCAPCD Rule 74.12

, Surface Coating of Metal Parts and
Products, is a rule designed to limit volatile organic compound (VOC) emission

from the application of coatings, surface preparation materials, and cleanup materials in metal parts and products coating operations. VOC limits for applicable coating materials are indicated in Section B. Recordkeeping Requirements are stipulated in Section D and Test Methods are outlined in

Section E

. Work Practices are not addressed in this Rule and the addition of this

is recommended. Rule 74.12 has exempted architectural coatings and coatings used on aerospace vehicles, motor vehicles, mobile equipment and marine, fresh water vessels and pleasure craft that are subject to other rules

. Changes from the approved SIP rule include:

1. Reduce d the current ROC limit for general (“all coatings except the following”) air

- dry coatings from 2.8 lb/gal of ROC to 2.3 lb/ gal.

2. Add ed the new coating category, “Multi

- component Coatings” with an ROC limit of 2.8 lb/gal.

3. Delete d the Laboratory Furniture category from the VOC limit list

4. Change d the High

- gloss coating category to be limited to two

- component coating

5. Reduce d th e ROC content limit for surface preparation and cleanup solvent to 25 g/l (0.21 lb/gal) of ROC.

6. Add ed new coating categories: Multi

- Component Coating, One

- Component Coating and High

- Volume

- Low

- Pressure (HVLP).

7. Identified new test methods for HVLP equipm ent.

8. Revise d capture and control efficiency limit and test methods.3

EPA EVALUATION

- The following criteria were used to evaluate the submitted

rule.

1. Enforceability

- 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 evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. RACT

– EPA’s Control Technique Guidelines (CTG) titled, “Control Techniques for Miscellaneous Metal and Plastic Parts Coatings” (EPA

453/R

- 08

- 003) and other state and local rules for this category were used to help evaluate the RACT requirements of CAA § 18 2( c )( 1 ).

3. Rule Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA § 110(l) and § 193 regarding SIP relaxation

.

The monitoring, recordkeeping, reporting and other requirements generally ensure

that the submitted rule can be enforced.

We believe Rule 74.12 implements RACT because it is generally as stringent as the 2008 CTG which has been issued for this activity with regard to coating of metal parts.

The new submittal strengthens previous SIP submittal and complies with CAA § 110(l) and § 193 regarding SIP relaxations. Several ROC limitations in Section B were lowered and the combined capture and control device efficiency was

increased from 85% to 90%.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RUL E REVISION

–

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

recommended for the next time the rule is amended :

1. Please incorporate all components of work practices, as defined in the 2008 CTG by expanding Section B

- 5.

2. Section E , Test Methods

, is very thorough . However, s everal formatting

error s are note d :

a. Please revise the date for ASTM D2879 to 199 7 . Only revisions specifically approved by the EPA can be used to demonstrate compliance with SIP.

b. Please revise the date for ASTM D1613 to the most current date

which is 2006

. This also complies with SCAQMD’s Rule 1107.4 c. Please revise Section E

- 6 to read, “The solids content of etching fillers shall be determined using 40 CFR 60, Appendix A, Method

24. ”

d. Please revise t he title for SCAQMD Method 311 to “Analysis of Percent Metallic Coating by Spectrographic Method.” And the date

may be added to the method number as: Method 311

- 91.

e. Please revise Section E

- 9 to , ” High

- Volume

- Low

- Pressure (HVLP) equipment shall be identified by either a test of air cap measurements or of an inlet pressure measurement that, when used with specifications published by the manufactu r er, establishes that the gun is being operated in Subsection G.25.”

3. We note that several new definitions were added. For clarity, please make the following corrections:

a. Catalytic incinerator s , as defined in Section G.9 use cobalt

- oxide, not cobalt (Ref EPA Directive EPA/452/B

- 02

- 001). Also, please note that

p latinum

- based catalysts are active for oxidation of sulphur containing VOCs but are rapidly deactivated in the presence of

c hlorine.

b. The AAMA reference for High Performance Architectural Coating in

Section G.23 does not exist and should be 2605

- 05 (Volu ntary Specification, Performance Requirements and Test Procedures for Superior Performing Organic Coatings on Plastic Profiles

. )

c. The formula in G.39 is inconsistent with composite partial pressure calculations used by BAAQMD (See Method 46 , Determination of Composite Partial Pressure of Volatile Organic Compounds in Cleaning Products ) and SCAQMD ( “BACT Guidelines for Non

- Major Polluting Facilities” 2

- 6

- 2006)

EPA ACTION

- EPA staff recommends a full approval of Rule 74.12 pursuant to CAA §110(k) (4) and §3 01(a).

ATTACHMENT S

-

1. VCAPC D Rule 74.12

, Surface Coating of Metal Parts and Products, as

submitted on April 26 , 20 0 5

.

2. VCAPC D Rule 74.12

, Surface Coating of Metal Parts and Products , as Submitted on January 10, 2010

.5

ADDITIONAL REFERENCES

-

1. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations, ” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988

.

2. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, Augu st 21, 2001

.

3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coating,” EPA

- 453/R

- 08

- 003, September 2008. http:// www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf