April 8, 2008 

Air Pollution Control Board 

800 South Victoria Avenue 

Ventura, CA 93009 

SUBJECT: PUBLIC HEARING TO ADOPT PROPOSED AMENDMENTS TO RULE 

74.12, SURFACE COATING OF METAL PARTS AND PRODUCTS 

RECOMMENDED ACTIONS:

1. Approve CEQA Notice of Exemption for Proposed Amended Rule 74.12, Surface 

Coating of Metal Parts and Products (Attachment 1). 

2. Approve and adopt the statutory rulemaking findings for Proposed Amended Rule 74.12, 

Surface Coating of Metal Parts and Products (Attachment 2). 

2. Approve and adopt proposed amendments to Rule 74.12, Surface Coating of Metal Parts 

and Products (Attachment 3). 

3. Direct the Clerk of the Board to forward two certified minute orders, and an affidavit of 

publication of the public hearing notice, for all proposed actions to the Air Pollution 

Control District. 

4. Direct Air Pollution Control Officer or his designee to file the Notice of CEQA 

Exemption pursuant to CEQA Guidelines Section 15062. 

FISCAL / MANDATES IMPACT:

Mandatory: Yes. Implements the provisions of Health and Safety Code section 40914(b)(2), 

"All Feasible Measures." 

Fiscal Impact: No impact; as proposed, the revisions will be implemented by existing staff. 

STATEMENT OF MATTER FOR BOARD CONSIDERATION:

Background

Rule 74.12, Surface Coating of Metal Parts and Products, was first adopted on November 19, 

1985, and has been the subject of several revisions since that time. The current proposed 

amendments to Rule 74.12 are necessary because the District's Air Quality Management Plan is 
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April 8, 2008 

required to expeditiously implement "every feasible measure" to reduce ozone precursor 

emissions by at least 5 percent annually (including reactive organic compounds, or ROC) to 

attain the California ambient ozone standard. See Health and Safety Code § 40914(b)(2). 

On October 9, 2001, your Board adopted an addendum to the Ventura County Triennial Plan that 

included a Feasible Control Measure to amend Rule 74.12 and attain emission reductions from 

operations involved in the surface coating of metal parts and products. In addition to the above, 

this proposal will implement Best Available Retrofit Control Technology (BARCT) for this 

stationary source category, as required by the California Clean Air Act. 

Proposed Rule 74.12 Amendments

1. Reduce the ROC limit for general air-dry one-component coatings from 2.8 pounds per 

gallon to 2.3 pounds per gallon (Subsection B.1). 

2. Create a new multi-component coating category with an ROC limit of 2.8 pounds per 

gallon; this category will exclude other listed specialty multi-component coatings. 

Both of these revisions are based on similar coating categories and emission standards in South 

Coast Air Quality Management District (SCAQMD) Rule 1107, which became effective on 

March 1, 1999. Compliant metal coatings are available and currently in use in both the 

SCAQMD jurisdiction (i.e, Los Angeles, Orange, San Bernardino and Riverside Counties) and 

Ventura County. 

3. Eliminate the special category in Subsection B.1 for laboratory furniture coatings. The 

only laboratory furniture manufacturer in the county, Hanson Lab Furniture, is using a 

very low-ROC coating material for its metal products. Any new lab furniture operation 

will be required to meet the Best Available Control Technology (BACT) requirements in 

Rule 26, New Source Review. 

4. Require the use of low-emission cleanup solvents for surface preparation, spray gun 

cleaning and general purpose cleanup in Subsection B.4. ROC content will be limited to 

no more than 25 grams per liter, or 0.21 pounds per gallon. This limit appears in the 

November 7, 2003, revision to SCAQMD Rule 1171, Solvent Cleaning Operations. This 

proposed amendment is considered feasible because compliant solvents, including 

acetone, acetone-blended solvents, and water, are available and in use at many metal 

parts paint shops in Ventura County. 

5. Add new definitions for "Capture Efficiency," "One-component Coating," and "Multicomponent Coating." Revise the definition of "High Gloss Coating" to incorporate a 

multi-component requirement. 

6. Revise the definition of "High Volume Low Pressure Application (HVLP)" and add an 

HVLP test standard in Subsection E.9 

7. Revise the capture efficiency test method in Subsection E.4. 
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April 8, 2008 

8. Make various text changes required to accommodate the proposed revisions. 

The effective date for these revisions is 90 days after the date of adoption. 

Discussion

Emission Reductions 

There are currently 53 facilities that coat metal parts or products in Ventura County. Of those, 

33 currently comply with the proposed amended surface coating requirements in Rule 74.12, and 

26 comply with the proposed cleaning solvent requirements. The 53 facilities have a total actual 

average emission rate of about 35 tons of ROC per year. The proposal will reduce actual ROC 

emissions from this source category by about 19 percent, or 6.64 tons per year. About 36 percent 

of the total annual emission reduction, or 2.40 tons per year, is a result of the change to the 

coating requirements. The remaining emission reductions (4.24 tons per year) are attributable to 

the proposed low-ROC cleaning solvent requirements. 

To determine actual emissions, staff reviewed annual inspection reports back to about 1999. 

These reports include coating and solvent descriptions and annual throughput totals. This 

information was used to determine average actual emission rates and material use. 

Cost Effectiveness 

To determine the cost of the proposed coating requirements, staff surveyed a number of coating 

suppliers and collected current prices for 14 complying single-component coatings; the average 

cost of these coatings is $41.95 per gallon. In addition, prices for four in-use coatings were also 

obtained; the average cost is $38.05. The difference in cost is $3.90 per gallon. Non-complying 

facilities were determined to use a total of 9,502 gallons of coating per year (Staff Report, 

Appendix C). On this basis, and assuming a 2.40 ton per year ROC reduction, the costeffectiveness of replacing certain 2.8 lb/gal coatings with 2.3 lb/gal coatings is $15,441 per ton 

of ROC reduced. 

For the cleaning solvent revisions, staff assumed that the ROC solvent currently in use is 

common lacquer thinner; local inquiries establish the cost of this solvent at $12.00 per gallon. 

The cost of three replacement complying solvents were also determined: these costs range from 

$13.00 per gallon to about $30 per gallon. Non-complying facilities were determined to use a 

total of 1,524 gallons of solvent per year (Staff Report, Appendix B). On this basis, and 

assuming an emission reduction of 4.24 tons of ROC per year (4.40 for acetone, an exempt 

solvent), the cost-effectiveness of the proposed low-ROC solvent requirement ranges from $359 

per ton of ROC reduced to $6,470 per ton. 

The District maintains a Best Available Control Technology (BACT) cost-effectiveness 

guideline of $18,000 per ton of ROC reduced. All of the above cost effectiveness estimates are 

below this threshold. Therefore, the proposed revisions are reasonable based on the cost of 

control. 
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April 8, 2008 

Public Participation

Staff held a public workshop on the proposed amendments to Rule 74.12 on August 30, 2007. 

No modifications to the proposed revisions were suggested. The Environmental Protection 

Agency, Region IX, made informal comments on the rule; these comments were incorporated 

into the proposed amended rule. The Advisory Committee unanimously recommended the 

proposed revisions to Rule 74.12 on February 26, 2008. 

PROPOSED FINDINGS:

Health and Safety Code Sections 40001(c), 40703, 40727, 40728.5 and 40920.6(a) direct that, 

prior to adopting the proposed revisions to Rule 74.12, your Board adopt findings of necessity, 

authority, clarity, consistency, nonduplication, reference, cost-effectiveness, incremental costeffectiveness, and socioeconomic impacts, based upon relevant information presented at the 

hearing. Health and Safety Code Section 40727.2 requires a written analysis, comparison, and 

consideration of existing air pollution regulations that apply to the same type of source. 

Therefore, if your Board approves the proposed revisions to Rule 74.12, it is recommended that 

your Board also adopt the proposed findings set forth in Attachment 1. 

District staff has determined that the proposed amendments to Rule 74.12 are categorically 

exempt from the requirements of the California Environmental Quality Act (CEQA) under 

Sections 15307 (Actions by Regulatory Agencies for Protection of Natural Resources) and 15308 

(Actions by Regulatory Agencies for Protection of the Environment) of the CEQA Guidelines. 

A Notice of Exemption with respect to this CEQA exemption is included as Attachment 2. 

This proposal has been reviewed by County Counsel. If you have any questions, please contact 

me at 645-1440 or Don Price at 645-1407. 

MICHAEL VILLEGAS 

Air Pollution Control Officer 

Attachments: 

 1. Proposed Notice of CEQA Exemption - Rule 74.12 

 2. Proposed Legislative Findings – Rule 74.12 

 3. Proposed Rule 74.12 (strikeout/underline, 2/29/08) 

 4. Proposed Rule 74.12 (clean version, 2/29/08) 

 5. Final Staff Report (2/29/08) 

 6. Advisory Committee Voting Record (2/26/08)