Ventura County Air Pollution Control District 

FINAL STAFF REPORT – February 29, 2008 

Revisions To Rule 74.12 

SURFACE COATING OF METAL PARTS AND PRODUCTS 

EXECUTIVE SUMMARY

Rule 74.12, Coating of Metal Parts and Products, was 

first adopted on November 19, 1985, and has been 

the subject of several revisions. The proposed 

revisions are required because, under the provisions 

of Health and Safety Code § 40914(b)(2), staff is 

required to demonstrate that the District's plan to 

attain the California ambient ozone standard provides 

for expeditious implementation of "every feasible 

measure" to reduce ozone precursor emissions 

(including reactive organic compounds, or ROC). 

On October 9, 2001, the Ventura County Air 

Pollution Control Board adopted an addendum to the 

Ventura County Triennial Plan that included a 

Feasible Measure to amend Rule 74.12. This 

proposal will also implement Best Available Retrofit 

Control Technology (BARCT) as required by the 

California Clean Air Act. 

Staff proposes two revisions to Rule 74.12. The first 

is to reduce the current ROC limit for general air-dry 

coatings ("all coatings except the following") from 

2.8 pounds of ROC per gallon (lb/gal) to 2.3 lb/gal. 

In addition, a new coating category, "Multi-Component Coatings," will be created with an ROC 

content limit of 2.8 lb/gal. This category excludes 

other listed specialty multi-component coatings. 

These revisions are based on similar coating 

categories and standards in South Coast Air Quality 

Management District (AQMD) Rule 1107, which 

became effective on March 1, 1999. Complying 

coatings are available and currently in use in both the 

AQMD and Ventura County. 

The second revision will reduce the ROC content 

limit for surface preparation and cleanup solvent to 

25 grams of ROC per liter (0.21 lb/gal). This limit 

appears in the November 7, 2003, revision to South 

Coast Air Quality Management District (SCAQMD) 

Rule 1171, Solvent Cleaning Operations. The 

proposal is feasible because complying solvents are 

available; these include acetone, acetone-blended 

solvents, and water. These solvents are currently in 

use at many metal parts paint shops in the county. 

The proposed revisions may affect approximately 27 

out of 53 facilities in Ventura County that coat metal 

parts or products. These facilities emit about 35 tons 

of ROC per year. The proposal will reduce ROC 

emissions by about 19 percent, or 6.64 tons per year. 

About 36 percent of the emission reduction results 

from the change to the coating requirements; the 

remainder results from the proposed low-ROC 

solvent requirements. 

The cost-effectiveness of replacing certain 2.8 lb/gal 

coatings with 2.3 lb/gal coatings is $15,441 per ton of 

ROC reduced. It is possible to estimate cost-effectiveness because complying high-performance, onecomponent topcoats and primers at 2.3 lb/gal are 

readily available. 

The cost-effectiveness of the proposed low-ROC 

solvent requirement can also be estimated because 

complying solvents are available. The cost-effectiveness of this proposal ranges from $359 per ton of 

ROC reduced to $6,470 per ton. 

Emission Source Inventory 

The 53 metal surface coating operations are currently 

permitted in Ventura County, as shown in Appendix 

A. City location, Standard Industrial Classification 

(SIC) Code, and SIC Code description are included. 

Of these, 29 are known to use complying solvent in 

their process; acetone, water, and other zero-ROC 

solvents are used. Three facilities use a combination 

of acetone and solvent, and six are unknown. Only 

18 sources are known to use a non-complying solvent 

(see Appendix B) 

In addition, 33 comply with the proposed 2.3 lb/gal 

coating requirement; 20 sources will be required to 

switch to lower-ROC coatings (see Appendix C). 
FINAL Staff Report – Rule 74.12 Page 2 

February 29, 2008 

PROPOSED REVISIONS 

Rule 74.12, Coating of Metal Parts and Products, was 

first adopted on November 19, 1985. The proposed 

revisions are required because, under the provisions 

of Health and Safety Code § 40914(b)(2), staff is 

required to demonstrate that "every feasible measure" 

to reduce ozone precursor emissions is being done. 

The following amendments are proposed to reduce 

ROC emissions at metal surface coating operations: 

1. Implement a lower ROC limit for general airdry one-component coatings and create a new 

multi-component coating category. Eliminate 

the special category for lab furniture coatings. 

2. Implement the use of low-emission cleanup 

solvents for spray gun and general purpose 

cleanup. ROC content will be limited to no 

more than 25 grams per liter (g/l), or 0.21 lb/gal. 

The effective date for these requirements is 90 days 

from the date of adoption by the Ventura County Air 

Pollution Control Board. 

Low-ROC Coating Requirements 

In Subsection B.1, staff proposes to reduce the ROC 

limit for general purpose, single component, air-dry 

coatings ("all coatings except the following") from 

2.8 lb/gal (340 g/l) to 2.3 lb/gal (275 g/l). In 

addition, a new coating category will be created for 

general multi-component coatings ; the ROC limit 

will be 2.8 lb/gal, or 340 g/l. The new category will 

exclude all multi-component coatings listed in the 

remainder of the ROC Limit chart. This proposal is 

based on the March 1, 1999, version of South Coast 

AQMD Rule 1107. The proposal does not change 

the ROC limit for baked coatings (2.3 lb/gal). 

In a related proposal, the high-gloss coating category 

will be limited to two-component coatings. Without 

this change, coating manufacturers may circumvent 

the revised ROC content limit above by relabeling 

one-component coatings for high gloss application. 

The current ROC content limit in the high gloss 

category is 3.5 lb/gal (420 g/l). 

Staff also proposes to delete the Laboratory Furniture 

coating category. This is possible because the only 

lab furniture coating company in the county, Hanson 

Lab Furniture, currently uses a 2.3 pounds per gallon 

waterborne baked acrylic enamel from Cardinal 

Coatings. This material is in compliance with the 

proposed one-component coating limit. Also, 

SCAQMD Rule 1107 does not include a separate 

category for lab furniture coating. 

To accomplish these changes, a modified ROC 

content chart will be added to Subsection B.1. A 

strikeout/underline version of the chart appears in 

Table 1. 

Low-Emission Cleanup Solvent 

Staff proposes to amend Subsection B.4 to limit the 

ROC content of all cleanup solvent used for spray 

gun cleaning and general purpose cleanup to 25 g/l. 

As previously noted, the effective date will be 90 

days from the date of adoption. The proposed 

revisions will appear in Subsection B.4 as follows: 

Surface Preparation and Cleanup:

a. After (90 days from date of adoption), no 

person shall use a material for substrate 

surface cleaning that has an ROC content 

exceeding 25 grams per liter of material.

a. On or before (90 days from date of adoption),

No no person shall use any material which 

contains more than 70 grams of ROC per 

liter of material for substrate surface 

cleaning. 

 Substrate surface cleaning performed in a 

degreasing unit operated in compliance with 

the requirements of Rules 74.6.1, 74.6.2 or 

74.6.3 as applicable shall not be subject to 

this ROC content limit. 

b. After (90 days from date of adoption), no 

person shall use a material for either spray 

equipment cleaning or cleanup that has an 

ROC content exceeding 25 grams per liter of 

material.

b. On or before (90 days from date of adoption),

No no person shall use organic solvent for 

cleanup unless: 

1) An enclosed gun washer or "low 

emission spray gun cleaner" that has 

been approved in writing by the APCO 

is properly used for spray equipment 

cleaning, and 

2) The ROC composite partial pressure of 

organic solvent used for cleanup, 

including spray equipment cleaning, is 

less than 45 mm Hg at 20°C. 
FINAL Staff Report – Rule 74.12 Page 3 

February 29, 2008 

Table 1 

Revisions ROC Content Chart in Subsection B.1 

 Air Dried Baked 

 Coating g/L lb/gal g/L lb/gal 

All coatings except 275 340 2.3 2.8 275 2.3 

for the following: 

Multi-Component

 not listed below 340 2.8 275 2.3

Camouflage 420 3.5 360 3.0 

Extreme Performance 420 3.5 360 3.0 

Etching Filler 420 3.5 420 3.5 

Heat Resistant 420 3.5 360 3.0 

High Gloss (2 Component) 420 3.5 360 3.0 

High Performance 

 Architectural 420 3.5 420 3.5 

High Temperature 420 3.5 420 3.5 

Laboratory Furniture 340 2.8 340 2.8

Metallic 420 3.5 360 3.0 

Mold Seal 420 3.5 420 3.5 

Pan Backing 420 3.5 420 3.5 

Pretreatment Wash Primer 340 2.8 275 2.3 

Silicone Release 420 3.5 420 3.5 

Solar Absorbent 420 3.5 360 3.0 

Vacuum Metalizing 420 3.5 420 3.5 

Other Proposed Revisions 

To accommodate the new coating categories, 

definitions of "One-Component Coating" and "MultiComponent Coating" are being added to Section G of 

the rule, as follows: 

31. "Multi-Component Coating": A coating 

requiring the addition of one or more 

separate reactive resins, commonly known as 

catalyst or hardener, prior to application to 

form an acceptable dry film.

32. "One-Component Coating": Any coating 

that is ready for application as it comes out 

of its container to form an acceptable dry 

film. A thinner or reducer, necessary to 

reduce the viscosity, is not considered a 

component.

In Subsection B.7, the Liquid Cleaning Material 

Compliance Statement will be amended to exclude 

ROC Composite Partial Pressure information. This 

information will not be necessary 90 days after the 

date of adoption. Other minor text changes in other 

subsections are also proposed. 

The definition of High Volume-Low Pressure 

(HVLP) spray equipment is being updated to be 

consistent with other District rules. The existing 

definition in Subsection G.24 will be replaced with 

the following: 

25. "High Volume-Low Pressure (HVLP)": 

Equipment used to apply coatings by means 

of a spray gun designed to be operated and 

operated between 0.1 and 10 pounds per 

square inch gauge (psig) air pressure 

measured dynamically at the center of the air 

cap and at the air horns.

The identification of HVLP spray equipment in the 

field has been an issue for District inspection staff. 
FINAL Staff Report – Rule 74.12 Page 4 

February 29, 2008 

To assist in this, staff proposes a paragraph in Section 

E, Test Methods, to specify methods of identification 

that may be used, as follows: 

9. High Volume-Low Pressure (HVLP) 

equipment shall be identified by either test 

air cap measurements or an inlet pressure 

measurement that, when used with 

specifications published by the 

manufacturer, establishes that gun is being 

operated as specified in Subsection G.16.

As suggested by USEPA on another coating rule, we 

propose to strike existing Subsection E.4 on capture 

and control efficiency determinations and replace it 

with the following: 

4. Capture efficiency shall be determined 

according to EPA Guidelines for 

Determining Capture Efficiency, dated 

January 9, 1995, and 40 CFR 51, Appendix 

M, Methods 204-204F as applicable. Control 

system efficiency shall be determined by 40 

CFR 60, Appendix A, Methods 18, 25 or 25A.

In addition, at EPA's suggestion, a definition of 

"Capture Efficiency" is being added to Section G: 

7. "Capture Efficiency": The percentage of 

ROC used, emitted, evolved, or generated by 

the operation, that are collected and directed 

to an air pollution control device.

DISCUSSION 

Emission Reductions 

The proposed amendments to Rule 74.12 will reduce 

actual ROC emissions from the coating of metal parts 

and products about 19 percent, or 6.64 tons per year 

(tpy). About 36 percent of the emission reduction 

(2.40 tpy) results from the change in coating 

requirements. The remaining 64 percent (4.24 tpy) 

results from the proposed 25 g/l threshold for 

cleaning solvents. 

Low-Emission Cleaning Solvent

Acetone is currently used by a number of metal 

surface coating operations for surface preparation, 

gun cleaning and general cleanup. Water is also 

used. Although acetone has a high vapor pressure 

and is extremely flammable, it is an exempt organic 

compound because its photochemical reactivity is 

low. 

Several vendors currently sell acetone-blend cleaning 

solvents that comply with the proposed revision. The 

performance of these cleaners has been demonstrated by their wide use in southern California. 

These cleaners include: 

• Pacific Coast Lacquer (PCL) 2085B 

• Oxsol 100 (PCBTF, Parachlorobenzotrifluoride) 

As shown in Appendix B, 18 of the 53 metal surface 

coating facilities in Ventura County use a known 

quantity of solvent for surface preparation and 

cleaning. Based on actual solvent use rates, the ROC 

solvent emission rate from these sources is 4.40 tons 

per year. If it is possible to use either water or an 

exempt solvent at these facilities, the entire 4.40 tons 

per year can be eliminated. If solvents meeting the 

25 gram/liter requirement are used, an ROC emission 

reduction of 4.24 tons per year is possible. 

Low-ROC Coating Requirements

Complying one-components coatings (including high 

gloss coatings) are available to meet the proposed 

ROC content limit of 2.3 pounds per gallon. A 

number of manufacturers offer compliant coatings; 

see Appendix D for more details. 

Of the 53 metal surface coating facilities in Ventura 

County, 20 are known to use single component 

coating materials that exceed 2.3 lb/gal (see Appendix C). The emission limit for these coatings is being 

reduced to 2.30 lb/gal from 2.80 lb/gal. Based on 

actual coating use, ROC emissions from these 

sources is 34.5 tpy. If coatings meeting the 2.30 

lb/gallon requirement are used, an ROC emission 

reduction of 2.40 tpy is possible. 

Cost-Effectiveness 

Low-Emission Cleaning Solvent

Both acetone and water are popular substitutes for 

non-exempt ROC solvents. Both options have an 

ROC content of zero. It also appears that most ROC 

solvent is used for spray gun cleaning. With this in 

mind, staff has attempted to estimate the cost of 

switching from an ROC solvent to either acetone or 

one of two other popular exempt cleaning materials. 
FINAL Staff Report – Rule 74.12 Page 5 

February 29, 2008 

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 acetone is about $14.00 per gallon, for a cost 

differential of $2.00 per gallon. As noted above, an 

ROC emission reduction of 4.40 tons per year can be 

assumed when an exempt solvent us used. Based on 

this information, and the annual county-wide solvent 

use total in Appendix B, the following cost 

effectiveness is estimated. 

($2/gal)*(1524 gal/yr) / (4.40 ton/yr) = $693 per 

 ton of ROC reduced 

Pacific Coast Lacquer (PCL) 2085B is a replacement 

solvent that meets the 25 gram/liter requirement. If 

this material is used, an ROC emission reduction of 

4.24 tons per year is possible. PCL states that the 

cost is about one dollar more than lacquer thinner.1

 

The resulting cost-effectiveness is: 

($1/gal)*(1524 gal/yr) / (4.24 ton/yr) = $359 per 

 ton of ROC reduced 

Another popular compliant solvent is PCBTF 

(Parachlorobenzotrifluoride), commonly known as 

Oxsol 100, an exempt compound. The local cost of 

this material is about $30 per gallon. Staff has no 

information on the usefulness of this material in 

metal surface coating. Nevertheless, the costeffectiveness of this material is: 

($18/gal)*(1524 gal/yr) / (4.24 ton/yr) = $6,470 

 per ton of ROC reduced 

The District maintains a Best Available Control 

Technology (BACT) cost-effectiveness guideline of 

$18,000 per ton of ROC reduced. All of the above 

estimates are well below this threshold. Therefore, 

the proposed revisions are reasonable based on the 

cost of control. 

Low-ROC Coating Requirements

As shown in Appendix D, a number of complying 

one-component topcoat and primers with an ROC 

content of 2.3 pounds per gallon or less are readily 

available. Staff surveyed a number of coating 

suppliers and got current prices for 14 complying 

coatings; the average cost of these coatings is $41.95 

per gallon. In addition, prices for four in-use costing 

were also obtained; the average cost is $38.05. The 

difference in cost is $3.90 per gallon. 

Based on this information, and the amount of annual 

coating use in Appendix C, the following cost 

effectiveness is estimated: 

($3.90/gal)*(9502 gal/yr) / (2.40 ton/yr) = $15,441 

 per ton of ROC reduced 

As noted above, the District maintains a BACT costeffectiveness guideline of $18,000 per ton of ROC 

reduced. The above estimate is below this threshold. 

Therefore, the proposed revisions to the coating 

requirements are reasonable and cost-effective. 

Incremental Cost-Effectiveness 

Health and Safety Code Section 40920.6 requires the 

performance of an incremental cost-effectiveness 

analysis for a regulation that identifies more than one 

control option to meet the same emission reduction 

objectives. Incremental cost-effectiveness is defined 

as the difference in costs divided by the difference in 

emission reductions between one level of control and 

the next more stringent level of control. 

No alternate control option is identified for the 

proposed 25 g/l ROC solvent requirement. 

Low-ROC Coating Requirements

Staff has identified one alternate control option that is 

not being proposed at this time. This control option 

would require the use of air-dried and baked topcoats 

with an ROC limit of 50 grams per liter. The primary 

coating technology available for this option is powder 

coating. 

For this option, powder coatings with an ROC 

content of less than 50 g/l are used in place of the 

solvent-based coatings at 380 g/l (2.8 lb/gallon). 

Information on the coatings under consider-ation in 

this control option appears in Table 2. 

Table 2 

Coating Data Used for 

Cost Analysis for Alternative Option 

Existing Coatings 

VOC (lbs/gal) 2.8 

Cost ($/gallon) $38.05 

Volume Solids (%) 50 

 

Zero ROC Coatings 

VOC (percent) 0 – 2 

Cost ($/pound) $4.25 

Volume Solids (%) 98 

Ratio of Solidsa

 0.51 

 a - Ratio of solids = coverage correction factor. 

Before the incremental cost-effectiveness is determined, the cost-effectiveness of the alternate control 

option must be calculated. Actual ROC emissions 
FINAL Staff Report – Rule 74.12 Page 6 

February 29, 2008 

from metal surface coating operations in Ventura 

County using liquid coatings are estimated to be 

24.65 tons per year; existing powder coating 

operations are not included in this total. This is equal 

to about 21,123 gallons of ROC coating per year. If 

only zero emission coatings were applied, emissions 

would be reduced to zero and all 24.65 tons per year 

of ROC would be eliminated. If a powder coating 

with a two percent ROC content were used, the 

reduction would be 24.16 tons per year. 

The cost of the proposal is two-fold – the cost of 

powder coating material and the cost of replacing all 

liquid ROC coating equipment with powder coating 

equipment. Cost estimates for the latter appear in an 

EPA/RTI discussion of powder coating operations.2

With respect to material applied, one gallon of ROCbased liquid paint is equal to about 7.4 pounds of 

powder coating.3

 Based on this information, and the 

annual liquid coating use noted above (and in 

Appendix E), the following cost effectiveness is 

estimated: 

(7.4 lb/gal)*(21,123 gal/yr) = 156,310 lb per year 

 of equivalent powder coating material 

The cost of powder coating materials ranges from 

$2.50 to $6.00 per pound, although specialty 

materials can exceed $25.00 per pound.2

 For this 

calculation, we assume $4.25 per pound. At this rate, 

the annual cost of material is: 

($4.25/lb)*(156,310 lb/yr) = $664,318 per year 

The comparable cost for liquid coating is: 

($38.05/gal)*(21,123 gal/yr) = $803,730 per year 

Therefore, powder coating materials save a total of 

$139,412 per year county-wide. 

The cost for new powder coating equipment can 

range from $50,000 for a batch system to $1,000,000 

or more for a conveyorized system.2

 The difference 

between batch and conveyor systems is the amount 

and size of product that can be processed in a given 

period of time. For most sources, we assume a small 

batch operation with a 10 x 10 x 20 ft oven will be 

used and the following purchases will be necessary: 

• Gun & feed system ..............................$5,000 

• Spray booth........................................$10,000 

• Cure oven...........................................$30,000 

• Pretreatment & cleaning system ........$10,000

 $55,000 

There are 46 metal surface coating operations in 

Ventura County that use liquid coating materials; 

seven other operations already use powder coating 

(See Appendix E). If we assume that there are 38 

small liquid ROC coating operations in Ventura 

County that could use the small system, a total of 

$2,090,000 in capital expenses will be necessary to 

change all coating systems to powder coating. Eight 

other operations are larger and make products that 

may require larger powder coating equipment. If we 

will assume that, in these cases, the equipment will 

cost $300,000, the total capital cost for these seven 

facilities will be $2,400,000. Note that differences in 

operating costs are not reflected in these calculations; 

among other things, powder coating requires less 

energy and less hazardous waste disposal. 

Assuming an equipment life of 10 years, the 

applicable capitol recovery factor applies: 

 10 years @ 8 percent = 0.149 

The capital recovery factor is used to annualize the 

one-time cost noted above. The county-wide 

annualized project cost is as follows: 

0.149 * $4,490,000 = $669,010 / year 

Therefore, the cost-effectiveness of the alternative 

proposal is: 

($669,010/yr)-($139,412/yr) / 24.16 tpy = $21,920

 per ton of ROC reduced. 

As noted above, the cost-effectiveness of the 

proposed revision is: 

($3.90/gal)*(9502 gal/yr) / (2.40 ton/yr) = $15,441

 per ton of ROC reduced 

On this basis, the annual cost of the proposed 

revision is: 

($3.90/gal)*(9502 gal/yr) = $37,058 per year 

Based on the definition, incremental cost-effectiveness is calculated as follows: 

($669,010/yr - $137,451/yr) - $37,058 = $22,635 

24.16 – 2.40 per ton of ROC reduced 

Incremental cost effectiveness "represents the added 

cost to achieve an incremental emission reduction 

between two control options."4

 This estimate is an 

independent economic assessment and is not related 

to the maximum absolute cost effectiveness for Best 

Available Control Technology (BACT) of $18,000 
FINAL Staff Report – Rule 74.12 Page 7 

February 29, 2008 

per ton of ROC reduced. Although the capital cost of 

the alternative control option is relatively high, the 

potential ROC emission reduction is also high. Note 

also that some companies may not be able to use 

powder coating in their particular manufacturing 

process. However, with better information about 

processes and costs from stakeholders, the alternative 

control option may be found to be both feasible and 

cost-effective. 

SOCIOECONOMIC IMPACT 

Health and Safety Code, Division 26, Part 3, Chapter 

6.5, section 40728.5, which became effective January 

1, 1992, requires that the District Board consider the 

socioeconomic impacts of any new or revised rule. 

The Board must evaluate the following socioeconomic information on proposed Rule 74.12. 

(1) The type of industries or businesses, including 

small business, affected by the rule or 

regulation.

 The adoption of these proposed amendments to 

Rule 74.12 will directly affect facilities that coat 

metal parts and products. These companies are 

listed in Appendix A of this report. 

 

(2) The impact of the rule amendments on 

employment and the economy of the region.

 Revisions to Rule 74.12 are not expected to 

have a significant impact on either employment 

or the economy of Ventura County. 

(3) The range of probable costs, including costs to 

industry or business, including small business, 

of the rule or regulation.

Overall the probable costs range from zero cost 

for those companies currently in compliance 

with the proposed amendments to $64,490 per 

year county-wide for those companies that 

switch coatings and solvent cleaners. 

(4) The availability and cost-effectiveness of 

alternatives to the rule or regulation being 

proposed or amended.

 One alternative control option has been 

identified; to require the use of a zero-ROC 

coating such as powder coating. The costeffectiveness of the option is estimated to be 

$21,920 per ton of ROC reduced. Although the 

cost of this option is relatively high, the ROC 

emission reduction potential is also high. With 

better information from stakeholders, this 

option may be both feasible and cost-effective. 

(5) The emission reduction potential of the rule or 

regulation.

 The anticipated emission reduction potential of 

the proposed rule is 6.64 tons per year of ROC 

emissions, a 19 percent reduction. These 

emission reductions result from the use lower 

ROC content air-dried coatings and the use of 

low ROC content cleaning solvents. 

(6) The necessity of adopting, amending, or 

repealing the rule or regulation in order to 

attain state and federal ambient air standards 

pursuant to Chapter 10 (commencing with 

Section 40910).

 Ventura County is classified as a moderate nonattainment area for federal Ambient Air Quality 

Standards for ozone. It is classified as a severe 

non-attainment area for state Ambient Air 

Quality Standards for ozone. These proposed 

rule amendments will reduce ROC emissions 

that are precursors to the formation of ozone. 

These emission reductions will help the District 

in its effort to attain both the federal and state 

ozone standards.

ANALYSIS OF EXISTING FEDERAL AND DISTRICT REGULATIONS 

Health and Safety Code Section 40727.2 requires 

Districts to compare the requirements of a proposed 

revised rule with other air pollution control 

requirements. These other air pollution control 

requirements include federal New Source 

Performance Standards (NSPS), federal National 

Emissions Standards for Hazardous Air Pollutants 

(NESHAPS), Best Available Control Technology 

(BACT) and any other District rule that applies to the 

same equipment. 

Federal NSPS and NESHAPS 

Source to which Rules 74.12 applies include any 

facility that coats metal parts and products. The 

existing federal regulation that applies to this source 
FINAL Staff Report – Rule 74.12 Page 8 

February 29, 2008 

type is the National Emission Standards for 

Hazardous Air Pollutants (NESHAPs) for Large 

Applicances, Metal Furniture, and Miscellaneous 

Metal Parts. This regulation is being proposed by the 

U.S. Environmental Protection Agency. 

District staff has evaluated the requirements of this 

federal regulation. We have determined that the 

proposed requirements of Rule 74.12 are at least as 

stringent as the federal regulation. 

BACT Requirements 

Health and Safety Code Section 40727.2 (a) requires 

that the proposed amendments to Rule 74.12 be 

compared with Best Available Control Technology. 

The CAPCOA Engineering Manager Rule 

Development Subcommittee developed guidance on 

this matter. Under this guidance, it was 

recommended that BACT be interpreted as a 

District’s BACT determination. 

A check of BACT Determinations made by the South 

Coast AQMD and ARB revealed a variety of control 

strategies for the coating of metal parts and products. 

The appropriate strategy depends on: the type, size, 

and shape of part; the process line speed; spray booth 

size and flow rate; and coating performance 

requirements. Type of control strategies include addon controls such as thermal oxidation for conveyorized booths, waterborne coatings, high-solid coatings, 

powder coatings and UV powder coatings. 

The BACT requirement for solvent cleaning of spray 

equipment is determined by SCAQMD Rule 1171. 

Effective November 7, 2003, the VOC content limit 

for spray equipment cleaners in Rule 1171 is 25 

grams of VOC per liter of solvent (0.21 lb/gal). 

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE / CEQA 

California Public Resources Code section 21159 

requires the District to perform an environmental 

analysis of the reasonably foreseeable methods of 

compliance if the proposed rule requires “the 

installation of pollution control equipment, or 

[specifies] a performance standard or treatment 

requirement...” The proposed revisions to Rule 74.12 

specify revised performance standards. 

The analysis must include the following information 

on the proposed revisions to Rule 74.12: 

(1) An analysis of the reasonably foreseeable 

environmental impacts of the methods of 

compliance.

(2) An analysis of the reasonably foreseeable 

mitigation measures. 

(3) An analysis of the reasonably foreseeable 

alternative means of compliance with the rule 

or regulation.

Table 3 lists all reasonably foreseeable compliance 

methods, the environmental impacts of those 

methods, and measures that could be used to mitigate 

the environmental impacts. The analysis indicates 

that the adoption of amendments to Rule 74.12 will 

not have a significant effect on the environment. 

CEQA Requirements 

Staff concludes that adoption of the proposed 

revisions to Rule 74.12 is within the scope of the 

categorical exemptions from the California 

Environmental Quality Act (CEQA) under state 

CEQA guideline Sections 15307, Protection of 

Natural Resources, and 15308, Protection of 

Environment, and that no exceptions to these 

categorical exemptions apply. 

MEETINGS AND COMMENTS

Environmental Protection Agency 

August 27, 2007 

In a telephone conversation, EPA suggested the 

addition of a "multi-component coating" definition. 

A definition of "capture efficiency" was also 

suggested. These changes were made; see pages 3 

and 4 of this report. In addition, EPA also suggested 

a few minor clarifications to the text. 

Public Workshop 

August 30, 2007

The public workshop was attended by one 

stakeholder. No significant changes to the rule were 

suggested. 
FINAL Staff Report – Rule 74.12 Page 9 

February 29, 2008 

Table 3 

Environmental Impacts and Mitigations of Methods of Compliance 

Compliance Methods (including all 

reasonably foreseeable alternative 

means of compliance) 

Reasonably Foreseeable 

Environmental Impacts 

Reasonably Foreseeable 

Mitigation Measures 

Reformulation of cleaning solvents Air Quality Impacts: Reformulation 

may result in the use of toxic 

materials. 

Operators may use cleaning 

solvents containing less toxic 

materials. Also the use of 

methylene chloride in cleaners is 

prohibited by the proposal. 

 

Water Impacts: Improper disposal of 

cleaning solvents may cause water 

impacts. 

Compliance with wastewater 

discharge standards and waste 

disposal requirements will 

mitigate these impacts. 

 

Human Health Impacts: 

Reformulation of cleaning solvents 

may contain more toxic compounds. 

Compliance with OSHA safety 

guidelines reduces these impacts. 

Also, methylene chloride, a 

carcinogen, will be prohibited. 

 

Flammability Hazard Impacts: 

The use of acetone in cleaning 

solvents may increase the likelihood 

of fire or explosions. 

Standard operating practices 

when dealing with flammable 

materials will mitigate this 

hazard. Proper ventilation and 

avoidance of heat sources or 

sparks are essential. 

Advisory Committee 

February 26, 2008

The committee asked about the depletion of noncomplying inventory; staff stated that 90 days should 

be enough time to accomplish the transition to 

complying compounds. A typographical error was 

noted in Subsection B.2.e. Staff stated that metal 

coating operations will be notified of the rule change 

by mail. The rule revision was unanimously recommended to the Air Pollution Control Board. 

REFERENCES

1. Telephone conversation with Ruben Laguna, 

PCL, 800/752-1566, February 7, 2006 

2. The Coatings GuideTM, RTI International and 

U.S.EPA Office of Research and Development, 

The National Risk Management Research 

Laboratory, October 03 2005, http://cage.rti.org/ 

altern_data.cfm?id=powder&cat=Economics 

3. Powder Coater's Manual, Roger Talbert, 

Chapter XI, Section 4, January, 1998, http:// 

www.coatings.de/pcmanual/pcmanual.cfm 

4. Incremental Cost-Effectiveness Guidance 

Document for Rule Development, California Air 

Pollution Control Officers Association, March 

26, 1998, page 2 

DISCLAIMER

This report contains references to company and product names to illustrate product availability. Mention of these 

names is not to be considered an endorsement by the Ventura County Air Pollution Control District. 
FINAL Staff Report – Rule 74.12 Page 10 

February 29, 2008 

APPENDIX A 

Permitted Metal Parts Coating Operations in Ventura County 

Facility Name Location SIC Code SIC Description 

1 A-1 Truck & Equipment Saticoy 7532 Auto Repair & Painting 

2 Air National Guard Channel Islands Port Hueneme 9711 National Security 

3 All Valley Wrought Iron Simi Valley 3499 Fabricated Metal Products 

4 Applied Powdercoat Oxnard 3549 Metalworking Machine Mfg. 

5 Artistica Metal Designs Ventura 2514 Metal Household Furniture 

6 B&R Scenery Camarillo 3999 Mfg. Industries, Other 

7 Bell Powder Coating Ventura 3479 Coating, Engraving, Other 

8 Bemco Simi Valley 3567 Industrial Furnace/Oven Mfg. 

9 Bend-Pac Santa Paula 3542 Machine Tool Mfg. 

10 Boeing – Santa Susana Simi Valley 3764 Rocket Testing 

11 C. D. Lyon Construction Ventura 1799 Paint & Sand / Steam Blasting 

12 Chapala Iron & Mfg. Company Ventura 3446 Ornamental Metal Work Mfg. 

13 Clark Engineering Construction Ventura 1799 Paint & Sand / Steam Blasting 

14 Custom Industrial Finishes Oxnard 3479 Coating, Engraving, Other 

15 Custom Iron Designs Simi Valley 3499 Fabricated Metal Products 

16 Data Exchange Corporation Camarillo 7378 Computer Maintenance & Repair 

17 Datron Advanced Tech Simi Valley 3812 Radar/Sonar System Mfg. 

18 Designworks/USA Newbury Park 7336 Commercial Art/ Graphic Design 

19 E. J. Harrison & Sons Saticoy 7532 Auto Repair & Painting 

20 Elite Metal Finishing Oxnard 3471 Electroplating 

21 ERG International Oxnard 2522 Metal Office Furniture 

22 Frias Wrought Iron Works Ventura 3446 Ornamental Metal Work Mfg. 

23 G&H Technology Inc. Camarillo 3678 Electronic Connectors 

24 G.I. Rubbish Company Simi Valley 7532 Auto Repair & Painting 

25 General Magnaplate Ventura 3471 Electroplating 

26 Haas Automation Oxnard 3549 Metalworking Machine Mfg. 

27 Hales Engineering Camarillo 3499 Fabricated Metal Parts 

28 Hanson Lab Furniture Newbury Park 3821 Lab Apparatus & Furniture 

29 Industrial Electric Motors Oxnard 7694 Motor Rewind Shop 

30 Int'l Power DC Power Supplies Oxnard 3679 Electronic Components – Other 

31 Malabar International Simi Valley 3728 Aircraft Parts/Equip. Mfg. 

32 Mares Wrought Iron Ventura 3446 Ornamental Metal Work Mfg. 

33 Metalcrafters Simi Valley 3499 Fabricated Metal Products 

34 Naval Base Ventura Co. – Pt. Mugu Point Mugu 9711 U.S. Naval Air Station 

35 North American Imaging Inc. Camarillo 5047 Medical / Dental / Hospital Equip. 

36 Oilfield Electric Company Ventura 7694 Motor Rewind Shop 

37 Original 22 Camarillo 2599 Furniture/Fixtures, Other 

38 Oxnard Public Works Equip. Yard Oxnard 9111 Government Agency 

39 Pentair Pool Products Moorpark 3648 Lighting Equipment, Other 

40 Power Machinery Center Oxnard 7359 Equipment Rental & Leasing 

41 Raypak Oxnard 3433 Swimming Pool Heater Mfg. 

42 Royal Coatings Simi Valley 3479 Coating, Engraving, Other 

43 Smith Precision Products Newbury Park 3569 Industrial Machinery Mfg. 

44 Southern California Gold Products Oxnard 3549 Metalworking Machine Mfg. 

45 Sun Welding Simi Valley 3499 Fabricated Metal Products 

46 T&T Truck & Crane Ventura 1389 Oilfield Services 

47 Trumeta Corporation Camarillo 3446 Ornamental Metal Work Mfg. 

48 Ventura Co. – Facilities & Grounds Ventura 9111 Government Agency 

49 Vista Landscape Lighting Simi Valley 3499 Fabricated Metal Products 

50 Vogue Sign Company Oxnard 3479 Coating/Engraving, Other 

51 Waterpik Technologies Moorpark 3433 Swimming Pool Heater Mfg. 

52 Weatherford Oil Country Ventura 3499 Fabricated Metal Products 

53 Weatherford U.S., L.P. Santa Paula 1389 Oilfield Services 
FINAL Staff Report – Rule 74.12 Page 11 

February 29, 2008 

APPENDIX B 

Metal Surface Coating Operations 

Requiring ROC Reductions - Solvent

Solvent Use and Emission Reduction Estimates

Facility # Permit Average Actual New Rule Difference Difference

 gal/yr gal/yr lb/gal lb/gal lb/gal ton/yr 

173 Oilfield Electric Company 70 38.40 4.00 0.21 3.79 0.07 

207 A-1 Truck & Equipment * 503.80 6.52 0.21 6.31 1.59 

596 Malabar International** * - - 0.21 - - 

636 Trumeta Corporation** * - - 0.21 - - 

712 Royal Coatings 100 91.14 6.76 0.21 6.55 0.30 

719 T & T Truck & Crane Service * 26.86 4.00 0.21 3.79 0.05 

841 Vogue Sign Company 120 2.80 0.50 0.21 0.29 0.00 

868 Chapala Iron & Mfg. Company 36 5.00 4.41 0.21 4.20 0.01 

1113 Designworks/USA 15 19.38 4.29 0.21 4.08 0.04 

1174 Hanson Lab Furniture 250 46.19 6.77 0.21 6.56 0.15 

1230 North American Imaging Inc. 125 25.76 6.57 0.21 6.36 0.08 

1308 Power Machinery Center 100 5.11 6.50 0.21 6.29 0.02 

1321 G & H Technology Inc. 138.6 12.26 2.91 0.21 2.70 0.02 

1335 Artistic Distribution Enamel 150 113.63 4.46 0.21 4.25 0.24 

7221 C.D. Lyon Construction Inc. 350 137.17 6.70 0.21 6.49 0.45 

7221 C.D. Lyon Construction Inc. 55 16.20 4.00 0.21 3.79 0.03 

7297 Weatherford Oil County 350 348.55 6.77 0.21 6.56 1.14 

7392 Hales Engineering 350 120.50 0.40 0.21 0.19 0.01 

7431 Elite Metal Finishing 10 10.82 6.77 0.21 6.56 0.04 

 

 * - Permitted solvent limit combined with coating limit 1523.54 4.63 4.24 

 ** - No actual use data Total Average Total 

 gal/yr Reduction Reduction 
FINAL Staff Report – Rule 74.12 Page 12 

February 29, 2008 

APPENDIX C 

Metal Surface Coating Operations 

Requiring ROC Reductions - Coatings

Coating Use and Emission Reduction Estimates 

Coating Use and Emission Reduction Estimates

Facility # Mix Permit Average Actual New Rule Difference Difference

 gal/yr gal/yr lb/gal lb/gal lb/gal ton/yr 

103 Custom Industrial Finishes 1 1785 1173.12 2.56 2.3 0.26 0.15 

173 Oilfield Electric Company 1 830 385.72 3.15 2.3 0.85 0.16 

207 A-1 Truck & Equipment 1 1941 928.18 2.57 2.3 0.27 0.12 

339 General Magnaplate 1 111 15.88 4.55 2.3 2.25 0.02 

596 Malabar Int'l 1 2760 lb 357.32 3.98 2.3 1.68 0.30 

605 Sun Welding 2 1412 524.46 3.50 2.8 0.70 0.18 

629 Air Nat'l Guard-Channel Island 1 125 36.17 3.50 2.3 1.20 0.02 

629 Air Nat'l Guard-Channel Island 1 75 5.70 2.84 2.3 0.54 0.00 

636 Trumeta Corporation 1 6000 lb 1432.58 2.46 2.3 0.16 0.11 

712 Royal Coatings 1 1500 275.86 2.80 2.3 0.50 0.07 

825 Intl Power DC Power Supplies 1 445 36.67 2.41 2.3 0.11 0.00 

841 Vogue Sign Company 1 500 50.09 2.60 2.3 0.30 0.01 

1113 Designworks/USA 1 82 62.30 3.85 2.3 1.55 0.05 

1308 Power Machinery Center 1 500 47.38 2.80 2.3 0.50 0.01 

1321 G & H Technology Inc. 1 76.5 4.80 7.03 2.3 4.73 0.01 

7086 G.I. Rubbish Company 1 3065 2365.79 2.80 2.3 0.50 0.59 

7086 G.I. Rubbish Company 1 400 324.63 3.50 2.3 1.20 0.19 

7232 Weatherford U.S., L.P. 1 300 83.50 2.83 2.3 0.53 0.02 

7336 Custom Iron Designs 1 2500 887.57 2.83 2.3 0.53 0.24 

7392 Hales Engineering 1 750 233.54 2.84 2.3 0.54 0.06 

7417 Applied Powdercoat, Inc. 1 200 200.00 2.80 2.3 0.50 0.05 

7431 Elite Metal Finishing 1 695 71.17 2.84 2.3 0.54 0.02 

 

 9502.43 0.91 2.40 

 Total Average Total 

 gal/yr Reduction Reduction
FINAL Staff Report – Rule 74.12 Page 13 

February 29, 2008 

APPENDIX D 

Partial List of Available Complying Coatings 
FINAL Staff Report – Rule 74.12 Page 14 

February 29, 2008 

APPENDIX D 

Partial List of Available Complying Coatings (con't) 
FINAL Staff Report – Rule 74.12 Page 15 

February 29, 2008 

APPENDIX E 

Metal Surface Coating Operations in Ventura County 

Summary of Calculation Results 
FINAL Staff Report – Rule 74.12 Page 16 

February 29, 2008 

APPENDIX E 

Metal Surface Coating Operations in Ventura County (Con't) 
FINAL Staff Report – Rule 74.12 Page 17 

February 29, 2008 

APPENDIX E 

Metal Surface Coating Operations in Ventura County (Con't) 
FINAL Staff Report – Rule 74.12 Page 18 

February 29, 2008 

APPENDIX F 

General Discussion of Metal Coating Technology 

Paints and coatings are made of materials that fall 

into the following four principal classes: pigments, 

solvents, binders, and additives. Pigments are finely 

divided solids of various shades used to give color, 

hiding, consistency, build, durability, and other properties to coatings. Binders, also called film formers, 

are oils, resins and plasticizers that go to make up the 

protective films. The solvents are the liquids added 

to most surface coatings to make them fluid enough 

for proper application. Solvents evaporate to leave a 

residue of pigment and binder to form the protective 

and decorative films by various drying and hardening 

processes. Solvents are also used for preparing the 

surfaces of various substrates and for cleanup. 

Finally, additives help to improve the performance 

characteristics in various ways. Additives may be 

driers, skinning inhibitors, biocides (including 

pesticides used as antifoulants) or wetting agents. 

The solvents used in the coating of metal parts and 

cleaning of spray equipment are the primary source 

of ROC emissions. These solvents evaporate 

releasing organic compounds to the atmosphere. The 

organic compounds photochemically react with 

oxides of nitrogen when exposed to ultraviolet 

radiation from sunlight to produce ozone. 

Coating Technology 

Today’s metal coatings are formulated with several 

resin systems that provide excellent durability and 

performance. Acrylics, polyurethanes, epoxies, polyesters, silicones, siloxanes, acrylates, and a variety of 

hybrids represent the majority of existing coating 

technologies. There are two ways to reduce coating 

emissions; either increase the solid content (resins 

and pigments) or replace the ROC solvent with water 

or exempt solvents. High-solids, multi-component, 

and Ultra-Violet (UV) curable coatings are in the 

former category, while waterborne and acetone-based 

coatings are in the second category. Most users have 

reduced solvent emissions by using either high solids, 

waterborne, or powder coatings. 

High-Solids Coatings 

High-solids coatings generally fall into the twocomponent air-dried category or the one-component 

heat-cured systems. An example of a new 

technology in the two-component, high-solids 

coatings is the engineered siloxane coatings from 

Ameron International. These air-dried twocomponent coatings (80 to 90 percent volume solids) 

can be applied by brush, roller, or spray without 

thinning. The ROC content of this coating is 120 

gram per liter and is a high-gloss, self-priming 

topcoat. This PSX resin from Ameron is the world’s 

first weatherable epoxy and contains the properties of 

both a high performance epoxy and an acrylic 

polyurethane in one coat. This coating has 

outstanding resistance to acid, corrosion, high 

humidity, and moisture. 

Another example of the new resin technology for 

high-solids coatings is Lyondell’s ACRYFLOW 

P120 liquid acrylic polyol. High performance 

coatings can be formulated with this resin and be 

sprayable at 2.1 pounds ROC per gallon. This resin 

provides improved crosslinking properties without 

increasing isocyanate demand, which leads to 

improved hardness, chemical resistance, durability 

and appearance at lower cost. Urethane coatings 

using this resin can have longer pot lives, which 

increases user process flexibility. Conversely, these 

coatings can also be formulated to dry quickly, 

another important cost and time saver. 

Waterborne Coatings 

Waterborne coatings reduce emissions simply 

because the solvent used is water. Almost all 

waterbornes contain some organic co-solvents or 

additives to provide added coating performance. 

Waterbornes can be formulated with many different 

resin systems: acrylics, epoxies, phenolic resins, 

polyamides and polyester. An example of the new 

waterborne coatings is DEVFLEX 4208QD from ICI 

Devoe Industrial Coatings. This is a premium quality 

waterborne acrylic gloss enamel. This coating 

features alkyd-like hardness and durability, 

exceptional adhesion, superior flow and leveling, fast 

dry, easy application, excellent gloss and color 

retention, low odor, and high hiding. The ROC 

content of this coating is about 205 grams per liter. 

Powder Coatings 

Powder coatings have long been used to coat metal 

parts because it is an efficient, no ROC, single-coat 

process that provides a high-quality, durable finish. 

Powder coatings offer the best way to reduce ROC 

emissions because they are 100% solids with very 

low emissions. Thermoplastic powders are applied to 

heated parts and immediately fuse to the metal 

substrate. Polyethylene, polypropylene, nylon, 

polyvinyl chloride, and polyester are commonly used 

thermoplastic resins. These are primarily functional 
FINAL Staff Report – Rule 74.12 Page 19 

February 29, 2008 

coatings rather than decorative because they are 

applied at many mils thickness. 

Thermoset powder coatings are principally used for 

decorative purposes and are applied from 1 to 3 mils 

thick. Epoxy, polyester and acrylic powder are the 

most common thermoset powders. They are used for 

shelving, bathroom fixtures, office and kitchen 

furniture, business machines and home appliances. 

Epoxy resins do not perform well outdoors because 

they may chalk when exposed to ultraviolet light. 

Hybrid resins of epoxy and polyester provide greater 

performance and easier application characteristics. 

Dow Chemical has developed new epoxy resin for 

powder coatings that have low-temperature (110o

C) 

and improved flow, high temperature resistance and 

maximum transparency in clear epoxy powder 

coatings. Low-temperature cure powders may be 

used for pre-assembled metal parts and plastic 

substrates. Improved flow allows use for decorative 

purposes with a smooth surface for application on 

metal shelving, file cabinets, appliances, furniture 

and general metal parts. 

Acrylic powders have an exterior durability similar to 

their liquid counterparts and may be used for heavy 

machinery, appliance exteriors and aluminum extrusions. Polyester and polyester triglycidylisocyanurate hybrid powders also have exterior uses such as 

aluminum and steel wheels and outdoor furniture. 

Use of powder coatings is a well-developed 

technology that has been used for the past 30 years 

and provides one of the most durable finishes 

available. Many types of parts are commonly 

powder-coated, including lawn and garden, 

appliance, and automotive. Recent developments 

include low-temperature cure of 250o

 F versus 300 to 

400 o

F for standard powders. Total annual sales of 

powder finishes in North America is about $1 Billion, 

approximately 10 percent of the total industrial 

finishes market. Other advances include metallic 

finishes and new application equipment that make 

color changes faster and easier. 

Ultraviolet-Cured Powder Coatings 

Ultraviolet (UV) curable coatings, inks, and 

adhesives have been used in a variety of industrial 

applications for more than 30 years; these include 

beverage cans, printing inks, overprint varnishes. 

UV curable powder coatings now make it possible to 

powder coat parts such as medium density fiberboard, plastics and preassembled and diecast metal 

parts. Plastics are difficult to powder coat because 

they are both heat sensitive and nonconductive. 

Additionally, galvanized and electroplated substrates 

that either outgas or are temperature sensitive can 

now be power coated without coating defects. 

UV powder coatings may also be a better option for 

massive metal parts, such as engine blocks, iron light 

pole bases, and I-beams that act as heat sinks during 

processing. With a traditional powder coating, the 

part surface must remain at high temperature to 

ensure adequate curing. A massive metal part 

absorbs the heat, which results in high-energy costs 

and long dwell and cool-down times. Since UV 

powder is not heat activated, both the oven 

temperature and dwell times can be reduced. This 

offers finishers new options and traditional powder 

coatings an ability to expand their market. 

UV coatings consist of monomers, oligomers, photoinitiators and additives. They exist in the acrylate 

chemical family as epoxy, urethane or polyester 

hybrids. Photoinitiators absorb UV or near Infra-Red 

light and generate free radicals that react with double 

bonds causing polymerization. So, one advantage is 

that the melt and flow step can be separated from the 

curing step, allowing superior flow out and leveling 

of the coating prior to crosslinking. Most UV powders melt and flow in infrared, convection or IR/convection ovens at 175o

F to 250oF for 2 to 10 minutes 

and cure in a UV oven in a matter of seconds. 

Application to variable geometries were difficult 

before three-dimensional curing equipment became 

available. In addition, heavily pigmented UV 

coatings that have outstanding opacity at low film 

loadings are available. Both textured and smooth 

coatings are available in a variety of colors, though 

not as many as traditional powders. Typical UV 

curing is a very fast, low temperature process that 

requires little floor space and produces high-quality 

coatings. Thus, with a UV powder, you get high 

material utilization, no ROCs, increased productivity, 

low-temperature curing and a high-quality coating. 

Compared to low-temperature thermal cure powders, 

UV powders provide a more durable finish, more 

flexibility and faster line processing. 

UV powders currently cost several times more than 

traditional powder coatings. But, costs are expected 

to drop as production volume increases. High 

material utilization, reduced floor space, increased 

line speeds will reduce costs in addition to reduced 

labor and energy costs.