10/12 Rule 74.24: 1

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 74.24 - MARINE COATING OPERATIONS

(Adopted 3/8/94, Revised 9/10/96, 11/11/03, 9/11/12)

A. Applicability

The provisions of this rule apply to any person who applies, specifies the use of, or 

supplies coatings for marine and fresh water vessels, drilling vessels, and navigational 

aids, and their parts or components, including any parts subjected to unprotected 

shipboard conditions. The provisions of this rule shall not apply to any stationary source 

whose sole Standard Industrial Classification (SIC) is 3732, Boat Building and Repair or 

4493, Marinas.

B. Requirements

1. Except as otherwise provided in this rule, no person shall apply a marine coating 

with an ROC content in excess of the following general limits, expressed as grams 

of ROC per liter of coating applied (g/l) or pounds per gallon (lb/gal), less water 

and exempt organic compounds (for low-solids coatings, the ROC content is 

based on a gram per liter of material basis): 

General Limits

Coating Category ROC Limit (g/l) ROC Limit (lb/gal)

Air Dried 340 2.8

Baked 275 2.3

2. Specialty Coating Limits: No person shall apply a marine coating with an ROC 

content in excess of the following limits, expressed as grams of ROC per liter of 

coating applied, less water and exempt organic compounds(for low-solids 

coatings, the ROC content is based on a gram per liter of material basis): 

Specialty Coating Limits

Coating Category ROC Limit (g/l) ROC Limit (lb/gal)

Air Flask Coatings 340 2.8

Antenna Coatings 340 2.8

Antifoulants Coatings

 Aluminum Substrates 560 4.7

 Other Substrates 400 3.3

Heat Resistant Coatings (Air Dried) 420 3.5

Heat Resistant Coatings (Baked) 360 3.0

High Gloss Coatings (Air Dried) 420 3.5

High Gloss Coatings (Baked) 360 3.0

High Temperature 500 4.2

Low Activation Interior 420 3.5

Military Exterior 340 2.8

Navigational Aids 340 2.8

Pretreatment Wash Primer 780 6.5
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Specialty Coating Limits

Coating Category ROC Limit (g/l) ROC Limit (lb/gal)

Repair and Maintenance Thermoplastic 340 2.8

Rubber Camouflage Coatings 340 2.8

Sealant for Wire-Sprayed Aluminum 610 5.1

Special Marking 420 3.5

Specialty Interior 340 2.8

Tack Coat 610 5.1

Undersea Weapons Systems Coatings 340 2.8

Wood Sealer 340 2.8

Zinc-Rich 340 2.8

3. Add-on Control Equipment Option: In lieu of complying with the provisions of 

Subsections B.1 or B.2, air pollution control equipment may be used provided 

that:

a. The combined control and capture efficiency reduces emissions by at least 

85 percent, by weight, and

b. Written approval for such equipment, in the form of an Authority to 

Construct and a Permit to Operate, is received from the Air Pollution 

Control Officer (APCO).

4. Surface Preparation and Cleanup Solvent: 

a. Until December 1, 2012, no person shall use ROC-containing materials for 

cleanup unless:

1) An enclosed gun washer or "low emission spray gun cleaner," 

which has been approved in writing by the APCO, is properly used 

for spray equipment cleaning, and 

2) The ROC composite partial pressure of the solvent used for 

cleanup, including spray equipment cleanup, is less than 45 mm Hg 

at 20oC.

Effective December 1, 2012, no person shall use ROC-containing 

materials for cleanup or for spray equipment cleaning unless the ROC 

content is 25 grams per liter of material or less.

b. Until December 1, 2012, no person shall use ROC-containing materials 

which have more than 200 grams of ROC per liter of material for substrate 

surface preparation prior to coating.
10/12 Rule 74.24: 3

Effective December 1, 2012, no person shall use ROC-containing 

materials which have more than 25 grams of ROC per liter of material for 

substrate surface cleaning prior to coating.

5. Storage of ROC-Containing Materials: All ROC-containing materials, including 

but not limited to, surface coatings, cleanup solvents, or surface preparation 

materials shall be stored in closed containers, which are nonabsorbent and do not 

leak.

6. Prohibition of Specification: No person shall solicit, require for use, or specify 

the application of any coating, if such use or application results in a violation of 

the provisions of this Rule. This prohibition shall apply to all written or oral 

contracts.

7. Compliance Statement Requirement: The manufacturer of any marine coating 

subject to this rule shall designate on the coating container or on separate data 

sheets the maximum volatile organic compound (VOC) content of the coating, as 

supplied. The VOC content shall be expressed as grams per liter of coating (less 

water and less exempt organic compounds). For zinc-rich coatings, in addition to 

the VOC content, the weight of total zinc per gallon of coating shall also be 

provided. For low-solids coatings, the VOC content shall be expressed as gram 

per liter of material basis.

8. Liquid Cleaning Material Compliance Statement: The manufacturer of liquid 

cleaning materials subject to this rule shall designate on product labels or data 

sheets the ROC or VOC content and ROC or VOC Composite Partial Pressure of 

cleaning materials as supplied. This designation shall include recommendations 

regarding mixing with any other ROC containing materials, and express the 

cleaning material ROC content when used in accordance with the manufacturer's 

recommendations. All letters and numbers used to designate ROC or VOC 

content on product labels shall be visible and legible.

C. Exemptions

1. The provisions of this rule shall not apply to:

a. Solid-film lubricants

b. The coating of stationary structures that are subject to Rule 74.2, 

Architectural Coatings, including, but not limited to bridges, piers, 

pontoons and installed offshore platforms.

c. The coating of metal parts that are subject to Rule 74.12, Surface Coating 

of Metal Parts and Products. Any marine coating applied to a vessel or to 

a component exposed to shipboard conditions shall be subject to Rule 

74.24.
10/12 Rule 74.24: 4

d. Aerosol coating products.

2. Section B of this rule, shall not apply to any stationary source that emits less than 

200 pounds of ROC in every rolling period of 12 consecutive calendar months 

from marine coating operations. Emissions from aerosol products, cold cleaners 

and vapor degreasers shall not be included in this determination. Any person 

claiming this exemption shall maintain monthly operational records to 

substantiate this claim.

3. Subsections B.1 and B.2 of this rule do not apply to any one coating provided:

a. No complying coating is available, and 

b. Total usage of all non-complying coatings has not exceeded 55 gallons in 

any calendar year. 

Any person claiming this exemption shall demonstrate the lack of available 

coatings to the APCO on an annual basis.

4. The provisions of this rule shall not apply to any stationary source whose sole 

Standard Industrial Classification (SIC Code), as identified by the APCO, is 3732, 

Boat Building and Repairing, or 4493, Marinas.

D. Recordkeeping 

1. Any person subject to this rule shall:

a. Maintain a current list of all coatings that provides all information 

necessary to evaluate compliance, including the following, as applicable:

1) The name and manufacturer of each coating and any catalysts and 

reducers used with each coating

2) Mix ratio of components used in coatings

3) ROC Content (less water and exempt organic compounds except 

for low-solids coatings, which are expressed as grams per liter of 

material basis), as applied

4) Category from Section B of each coating used

b. Maintain records which show the following foreach ROC-containing 

material used for cleanup, including equipment cleaning, and each ROCcontaining material used for substrate surface cleaning:

1) Type

2) ROC content in grams per liter of material

3) Composite ROC partial pressure of organic solvent (where 

applicable)
10/12 Rule 74.24: 5

c. Maintain records of the monthly volume of each complying coating and 

ROC-containing liquid used for equipment cleanup and surface 

preparation, and daily volume of each noncompliant coating used. Any 

person claiming the coating small-use exemption in Subsection C.3 shall 

maintain records of each exempt coating used on a monthly basis. 

d. Any person using an emission control system as a means of complying 

with this rule shall maintain daily records of key system operating and 

maintenance procedures which will demonstrate continuous operation and 

compliance of the emission control device during periods of emission 

producing activities. 

2. All records shall be retained for at least two (2) years from the date of each entry 

and shall be available to District personnel upon request.

E. Test Methods

1. The ROC and solids content of all coatings and cleaning solvents shall be 

determined using EPA Reference Method 24 (40 CFR Part 60, Appendix A), 

“Determination of Volatile Matter Content, Water Content, Density, Volume 

Solids, and Weight Solids of Surface Coatings.”

2. Exempt organic compounds shall be determined using ASTM D4457-91, “Test 

Method for Determination of Dichloromethane and 1,1,1-Trichloroethane in 

Paints and Coatings by Direct Injection into a Gas Chromatograph.”

3. 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.

Methods 204, Criteria for and Verification of a Permanent or Temporary Total Enclosure 

Method 204A, VOC content in Liquid Input Stream

Method 204B, VOC Emissions in Captured Stream

Method 204C, VOC Emissions in Captured Stream (Dilution Technique)

Method 204D, VOC Emissions in Un-captured Stream from Temporary Total Enclosure

Method 204E, VOC Emissions in Un-captured Stream from Building Enclosure, and

Method 204F, VOC Content in Liquid Input Streams (Distillation Approach)

Control system efficiency shall be determined by 40 CFR 60, Appendix A, 

Method 18, “Measurement of Gaseous Organic Compound Emissions by Gas 

Chromatography”, Method 25, “Determination of Total Gaseous Nonmethane 

Organic Emissions as Carbon” or Method 25A, “Determination of Total Gaseous 

Organic Concentration Using a Flame Ionization Analyzer.”

4. ROC composite pressure of a solvent shall be calculated using a widely accepted 

published source such as: Boublik, T., V. Fried and E. Hala, "The Vapor Pressure 
10/12 Rule 74.24: 6

of Pure Substances," Elsevier Scientific Publishing Co., New York (1973), Perry's 

Chemical Engineer's Handbook, McGraw-Hill Book Company, CRC Handbook 

of Chemistry and Physics, Chemical Rubber Publishing Company (1986-87), and 

Lange's Handbook of Chemistry, John A. Dean, editor, McGraw-Hill Book 

Company (1985). The true vapor pressure of a component in a solvent mix may 

be determined by ASTM Method D2879-97, “Test Method for Vapor PressureTemperature Relationship and Initial Decomposition Temperature of Liquids by 

Isoteniscope.” The ROC composite pressure of a solvent mix consisting entirely 

of ROC may be determined by ASTM Method D2879-97.

5. The active and passive solvent losses from spray gun cleaning systems shall be 

determined using SCAQMD's "General Test Method for Determining Solvent 

Losses from Spray Gun Cleaning Systems" dated October 3, 1989. The test 

solvent for this determination shall be any lacquer thinner with a minimum ROC 

composite partial pressure of 105 mm of Hg at 20 oC, and the minimum test 

temperature shall be 15 oC.

6. The measurement of acid content and solid content of pretreatment wash primers 

shall be done in accordance with ASTM Method D 1613-96, “ASTM Standard 

Test Method for Acidity in Volatile Solvents and Chemical Intermediates Used in 

Paint, Lacquer, and Related Products,” and ASTM Method D 2369-95, “Standard 

Test Method for Volatile Content of Coatings,” respectively. 

7. The measurement of the zinc content of a coating shall be determined in 

accordance with South Coast Air Quality Management District Method 311, 

"Determination of Percent Metal in Metallic Coatings by Spectrographic Method."

F. Violations

Failure to comply with any provision of this rule, including the requirement to maintain 

records or supply VOC or ROC information, shall constitute a violation of this rule. 

G. Definitions:

1. "Active Solvent Losses": The active solvent losses are the emissions during all 

steps of a spray gun equipment cleaning operation and are expressed in units of 

grams of solvent loss per cleaning cycle. 

2. "Aerosol Coating Product"; A pressurized coating product containing pigments or 

resins that dispenses product ingredients by means of a propellant, and is 

packaged in a disposable can for hand held application, or for use in specialized 

equipment for ground traffic/marking applications.

3. "Air Dried Coating": Any coating that is cured at a temperature below 90°C 

(194°F).
10/12 Rule 74.24: 7

4. "Air Flask Coating": A coating applied to the interior surfaces of high pressure 

breathing air flasks to provide corrosion resistance and which is certified safe for 

use with breathing air supplies. 

5. "Antenna Coating": Any coating applied to equipment and associated structural 

appurtenances that are used to receive or transmit electromagnetic signals. 

6. "Antifoulant Coating": Any coating applied to the underwater portion of a vessel 

to prevent or reduce the attachment of biological organisms and registered with 

the Environmental Protection Agency (EPA) as a pesticide. 

7. "Baked Coating": Any coating that is cured at a temperature at or above 90°C 

(194°F).

8. “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.

9. "Cleanup": The removal of uncured coating from any surface. 

10. "Coating": A material that is applied to a surface and forms a film in order to 

beautify and/or protect such surface.

11. "Exempt Organic Compounds": As defined in Rule 2, Definitions, of these Rules.

12. "Grams of ROC per liter of Coating, less water and exempt organic compounds": 

The weight of ROC per combined volume of ROC and coating solids calculated 

using the following equation:

Grams of ROC per Liter of Coating 

Less Water and Exempt Organic Compound = Ws - Ww - Wes

 Vm - Vw - Ves

where Ws = Weight of volatile compounds (grams)

Ww = Weight of water (grams)

Wes = Weight of exempt organic compounds (grams)

Vm = Volume of material (liters)

Vw = Volume of water (liters)

Ves = Volume of exempt organic compounds (liters)

13. "Grams of ROC per Liter of Material": The weight of ROC per volume of 

material shall be calculated using the following equation:

Grams of ROC per Liter of Material 

 = Ws - Ww - Wes

 Vm 
10/12 Rule 74.24: 8

Where Ws = Weight of volatile compounds (grams)

Ww = Weight of water (grams)

Wes = Weight of exempt organic compounds (grams)

Vm = Volume of material (liters)

14. "Gun Washer": Electrically or pneumatically operated system that is 

designed to clean spray application equipment while enclosed. A gun washer may 

also be considered a gun cleaning system that consists of spraying solvent into an 

enclosed container using a snug fitting.

15. "Heat Resistant Coating": Any coating which during normal use must withstand 

temperatures of at least 204°C (400°F).

16. “High Gloss Coating”: Any coating which achieves at least 85 percent 

reflectance on a 60o meter when tested in accordance with ASTM D-523.

17. "High Temperature Coating": Any coating which must withstand temperatures of 

at least 426°C (800°F).

18. "Low-Activation Interior Coating": A coating used on interior surfaces aboard 

ships to minimize the activation of pigments on painted surfaces within a 

radiation environment. 

19. "Low emission spray gun cleaner": Any properly used spray equipment cleanup 

device which has passive solvent losses of no more than 0.6 grams per hour and 

has active solvent losses of no more than 15 grams per operating cycle as defined 

by the test method in Subsection E.5.

20. “Low-Solids Coatings”: Any product that has less than one pound of solids per 

gallon of material (120 grams or less of solids per liter of material). Such solids 

are the non-volatiles remaining after a sample is heated at 110o

C for one hour.

21. "Marine Coating": Any coating, except unsaturated polyester resin (fiberglass) 

coatings, intended by the manufacturer to be applied to marine or fresh water 

vessels, and their appurtenances, and to navigational aids.

22. "Military Exterior": Any exterior topcoat intended by the manufacturer to be 

applied to military vessels (including US Coast Guard) that are subject to 

specified chemical, biological, and radiological washdown requirements.

23. "Navigational Aids Coating": Any coating that is used to recoat in-use buoys or 

other Coast Guard waterway markers.

24. "Operating Cycle": An operating cycle consists of all steps carried out during a 

cleaning operation.
10/12 Rule 74.24: 9

25. "Passive Solvent Losses": The passive solvent losses are the emissions from 

spray gun cleaning equipment when the equipment sits idle between cleaning 

cycles and are a result of natural evaporation from the equipment.

26. "Pretreatment Wash Primer": Any coating which contains at least 1/2-percent 

acids, by weight, to provide surface etching and contains no more than 12 percent 

solids, by weight. 

27. "Reactive Organic Compounds (ROC)": As defined in Rule 2, Definitions, of 

these Rules. The term "volatile organic compound"(VOC) is equivalent to ROC.

28. "Repair and Maintenance Thermoplastic Coating": Any vinyl, chlorinated rubber, 

or bituminous resin coating used for partial recoating over the same coating 

system.

29. ROC Composite Partial Pressure": The sum of the partial pressures of the 

compounds defined as ROCs. ROC composite partial pressure is calculated as 

follows:

( )( )

( ) PP

W VP

MW

W

MW

W

MW

W

MW

c

i i

i i

n

w

w

e

e e

n i

i i

n = 



 



 + 



 



 + 



 





=

= =

∑

∑ ∑

1

1 1

Where:

Wi = Weight of the "i"th ROC compound, in grams

Ww = Weight of water, in grams

We = Weight of the "e"th exempt organic compound, in grams

MWi = Molecular weight of the "i"th ROC compound, in g/(g-mole)

MWw = Molecular weight of water, in g/(g-mole)

MWe = Molecular weight of the "e"th exempt organic compound, in g/(g-mole)

PPc = ROC composite partial pressure at 20 C, in mm Hg 

VPi = Vapor pressure of the "i"th ROC compound at 20 C, in mm Hg.

30. "Rubber Camouflage Topcoat": A specially formulated epoxy coating, used as a 

camouflage topcoat for exterior submarine hulls and sonar domes lined with 

elastomeric material, which provides resistance to chipping and cracking of the 

rubber substrate.

31. "Sealant for Wire-Sprayed Aluminum": A coating of up to one mil (0.001 inch) 

in thickness of an epoxy material which is reduced for application with an equal 

part of an appropriate solvent (naphtha or ethylene glycol monoethyl ether), for 

use on wire-sprayed aluminum surfaces. 

32. "Solid Film Lubricant": A very thin coating consisting of a binder system 

containing as its chief pigment material one or more of the following: 
10/12 Rule 74.24: 10

molybdenum disulfide, graphite, polytetrafluoroethylene (PTFE) or other solids 

that act as a dry lubricant between faying surfaces.

33. "Specialty Interior Coating": An extreme performance coating used on interior 

surfaces aboard ships. This coating has fire retardant properties in addition to 

military physical performance requirements. 

34. "Special Marking Coating": Any coating used for items such as flight decks, 

ships' numbers, and other safety or identification applications. 

35. "Substrate Surface Cleaning": Cleaning of a substrate to remove dirt, oils, and 

other contaminants. Substrate surface cleaning is typically done prior to the 

application of surface coatings, adhesive bonding materials, or sealants. Stripping 

of cured paints or adhesives is not considered to be substrate surface cleaning.

36. "Tack Coat": An epoxy coating of up to two mils thick applied to an existing 

epoxy coating that has aged beyond the time limit specified by the manufacturer 

for application of the next coat. 

37. "Undersea Weapons Coating": A coating applied to any component of a weapons 

system intended for exposure to a marine environment and intended to be 

launched or fired undersea.

38. "Volatile Organic Compound" (VOC): Shall have the same meaning as Reactive 

Organic Compounds (ROC) as defined in Rule 2 of these Rules.

39. "Wired-Sprayed Aluminum": A molten aluminum coating applied to a steel 

substrate using oxygen fueled combustion spray methods. 

40. "Wood Sealer": A coating formulated for and intended by the manufacturer to be 

applied to wood in order to prevent subsequent coatings from being absorbed into 

the wood.

41. "Zinc-Rich Coating": A coating that contains more than 8 pounds of zinc per 

gallon of coating (as applied), used for the express purpose of providing corrosion 

protection.