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

December, 2010
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Agency: Ventura County Air Pollution Control District 

(VCAPCD)

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. Reduced 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. Added the new coating category, “Multi-component Coatings” with an ROC 

limit of 2.8 lb/gal.

3. Deleted the Laboratory Furniture category from the VOC limit list

4. Changed the High-gloss coating category to be limited to two-component 

coating

5. Reduced the ROC content limit for surface preparation and cleanup solvent 

to 25 g/l (0.21 lb/gal) of ROC. 

6. Added new coating categories: Multi-Component Coating, One-Component 

Coating and High-Volume-Low-Pressure (HVLP).

7. Identified new test methods for HVLP equipment.

8. Revised capture and control efficiency limit and test methods.
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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” (EPA453/R-08-003) and other state and local rules for this category were used to 

help evaluate the RACT requirements of CAA §182(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 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. 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, several formatting 

errors are noted:

a. Please revise the date for ASTM D2879 to 1997. 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.
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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 the 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 manufacturer, 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 incinerators, as defined in Section G.9 use cobalt-oxide, not 

cobalt (Ref EPA Directive EPA/452/B-02-001). Also, please note that 

platinum-based catalysts are active for oxidation of sulphur 

containing VOCs but are rapidly deactivated in the presence of 

chlorine. 

b. The AAMA reference for High Performance Architectural Coating in 

Section G.23 does not exist and should be 2605-05 (Voluntary 

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 §301(a). 

ATTACHMENTS -

1. VCAPCD Rule 74.12, Surface Coating of Metal Parts and Products, as 

submitted on April 26, 2005.

2. VCAPCD Rule 74.12, Surface Coating of Metal Parts and Products, as 

Submitted on January 10, 2010. 
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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, August 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