CALIFORNIA AIR RESOURCES BOARD



### APCD/AQMD RULE EVALUATION FORM -- Page 1

(Electronic Format)

I. GENERAL INFORMATION

District: Placer County Air Pollution Control District

Rule No(s): 245 Date adopted/Amended/Rescinded: 08/20/2009

Rule Title(s): Surface Coating of Metal Parts and Products

Date Submitted to ARB: September 18, 2009

If an Amended Rule, Date Last Amended (or Adopted): 12/11/08

Is the Rule Intended to be Sent to the U.S. EPA as a SIP Revision? Yes No ( If No, do not complete remainder of form)

District Contact: John Finnell Phone Number: (530) 745-2324 E-mail Address: jfinnell@placer.ca.gov

Narrative Summary of New Rule or Rule Changes: New Rule Amended Rule

Rule 245, Surface Coating of Metal Parts and Products, wa s originally adopted by the District on December 8,

2009 to meet Reasonably Available Control Technology – State Implementation Plan (RACT SIP) requirements.

In September 2008, toward the end of the time period t hat Rule 245 was being finalized, the U.S. Environmental

Protection Agency released "Control Techniques Guide lines (CTG) for Miscellaneous Metal and Plastic Parts

Coatings.” The CTG provided updated guidance for deter mination of Reasonably Available Control Technology

for metal surface coating operations. Due to the timing of the CTG, the District was not able consider the CTG in

Rule 245.

This Staff Report addresses amendments that are pr oposed to Rule 245 based on the CTG. This rule

amendment fulfills the District requirement to adopt a meas ure that incorporates the CTG within one year of the

CTG’s release.

Changes to the Rule include:

Section 105 Exemptions for Spec ific Operations and Coatings

• Elimination of the exemption for stripping of cured coatings, cured adhesives, and cured inks.

• Elimination of the exemption for the coating categories of aircraft, aer ospace vehicles, coils, and conformal

coatings.

• Elimination of the exemption for hand-lettering, electr ocoating, optical anti-reflective coatings, mobile

equipment, and vacuum-metalizing.

• Clarifying a partial exemption for repair and touchup – only exempt from application method requirements.

• Retention of a partial exemption for coating operati ons used for stencil, safety indicating, solid film

lubricants, electrical insulating and thermal conduction, and magnetic dat a storage discs – adding a requirement

to meet work practice standards and retaining recordkeeping requirements.

Section 301 VOC Limits

• Deletion of VOC limits for categories of alumi num coatings, nonskid, and solid film lubricants.

• Addition of VOC limits for categories of electr ical insulating varnish and military specification.

• Placement of iridescent coatings with the metallic coating category.

• Elimination of “All Other” coating category.

Section 302 Application Methods

• Requirement that U.S. EPA approv e alternative application methods.

Section 304 Work Practice Requirements

• Addition of a new section that addresses work pr actice requirements for all operations – including

minimizing spillage and usage of closed containers to transport and store and dispose of VOC containing

materials.CALIFORNIA AIR RESOURCES BOARD



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Section 503 Test Methods

• New Section 503.9 specifies that a violation may be determined by any one of the specified test methods.

Pollutant(s) Regulated by the Rule (Check): ROG (NOx) SO2

(CO) PM TAC (name):

II. EFFECT ON EMISSIONS

Complete this section ONLY for rules that, when implemented, w ill result in quantifiable changes in emissions. Attach referenc e(s) for emission factor(s)

and other information. Attach calculation sheet showi ng how the emission information provided below was determined

.

Net Effect on Emissions: Increase Decrease N/A

Emission Reduction Commitment in SIP for this Source Category: 0

Inventory Year Used to Calcul ate Changes in Emissions: N/A Area Affected: N/A

Future Year Control Profile Estimate (Provide information on as many years as possible) :

N/ACALIFORNIA AIR RESOURCES BOARD



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5/1/2002 3

Baseline Inventory in the SIP for the Control Measure: N/A

Emissions Reduction Commitment in the SIP for the Control Measure: N/A

Revised Baseline Inventory (if any): N/A

Revised Emission Reduction Estimate (if developed): N/A

Note that the district’s input to the Rule Evaluation Form will not be used as input to the ARB’s emission forecasting and

planning.

III. SOURCES/ATTAINMENT STATUS

District is: Attainment Nonattainment Split

Approximate Total Number of Small (<100 T PY) Sources Affected by this Amendment: 4

Percent in Nonattainment Area: 100 %

Number of Large (> 100 TPY) Sources Controlled: 0 Percent in Nonattainment Area: N/A %

Name(s) and Location(s) (city and county) of Large (> 100 TPY) Sources Controlled by Rule (Attach additional sheets as

necessary) : N/A

IV. EMISSION REDUCTION TECHNOLOGY

Does the Rule Include Emission Limits that are Continuous? Yes No

If Yes, Those Limits are in Section(s) 301, Limits on VOC Content of Coatings for Metal Parts and Products of the Rule.

Other Methods in the Rule for Achieving Emission Reducti ons are: Section 302, Application Methods; Section 303,

Surface Preparation and Cleanup Requirement s; Section 304, Work Practices; and Section 305, Emission Control

Equipment.

V. OTHER REQUIREMENTS

The Rule Contains:

Emission Limits in Section(s): 301, Limits on VO C Content of Coatings for Metal Parts and Products Work Practice

Standards in Section(s): 304, Work Practices

Recordkeeping Requirements in Section(s): 501, Recordkeeping Reporting Requirements in Section(s): 501.4,

Retention of RecordsCALIFORNIA AIR RESOURCES BOARD



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VI. IMPACT ON AIR QUALITY PLAN

No Impact Impacts RFP Impacts attainment

Discussion: The Rule amendment was adopted to incorporate t he U.S. Environmental Protec tion Agency's most recently

released “Control Techniques Guidelines (CTG) fo r Miscellaneous Metal and Plastic Parts Coatings.”