SAN DIEGO COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 67.5 - PAPER, FILM AND FABRIC COATING OPERATIONS
(Effective 5/9/79: Rev. Adopted & Effective 5/15/96)

(a) APPLICABILITY

Except as otherwise provided in Section (d), this rule is applicable to any paper, fabric and/or film coating application process.

(b) EXEMPTIONS

The provisions of Subsections (d)(1)(i) and (d)(1)(ii) of this rule shall not apply to:

  1. Any coating application process which emits less than 14.3 lbs (6.5 kilograms) of volatile organic compounds per day;

  2. Laboratory equipment used exclusively for research and development operations for any paper, fabric and/or film coating application process not involving the use of heating ovens, provided that emissions from such operations are less than 20.0 lbs (9.1 kilograms) of volatile organic compounds (VOC) per day.

(c) DEFINITIONS (Rev. Effective 5/15/96)

  1. "Application Process" means any portion of a paper, fabric, or film coating line where surface coatings are applied and/or cured, including the coating applicator and heating ovens.

  2. "Cleaning Materials" are VOC containing materials used for cleaning hands, tools, application equipment and work area.

  3. "Exempt Compound" means the same as defined in Rule 2. (Rev. Effective 5/15/96)

  4. "Fabric Coating" means any decorative or protective coating or reinforcing material applied on or impregnated into textile fabric or vinyl coated textile fabric or vinyl sheets.

  5. "Film Coating" means any coating applied in web coating process on any film substrate other than paper or fabric, including, but not limited to typewriter ribbons, photographic film, magnetic tape, and metal foil gift wrap, but excluding coatings applied to packaging used exclusively for food and health-care products for human or animal consumption.

  6. "Liquid Leak" means any visible leak of liquid VOC at a rate in excess of three drops per minute.

  7. "Laboratory Equipment" means equipment which: a) is under direct immediate and exclusive control of a laboratory director; and b) used for the sole purpose of conducting studies or tests to develop a new or improved product or service.

  8. "Paper Coating" means any coating applied on or impregnated into paper, including, but not limited to, adhesive tapes and labels, book covers, post cards, office copier paper, drafting paper, and pressure sensitive tape.

  9. "Volatile Organic Compounds (VOC)" for the purpose of this rule means any compound containing at least one atom of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and exempt compounds which may be emitted to the atmosphere during the application, drying and curing operations. VOC content of coatings is expressed in grams of VOC per liter of coating, as applied, less water and less exempt compounds. VOC content of cleaning materials is expressed in grams of VOC per liter of material.

(d) EMISSION STANDARDS

  1. A person shall not use or apply any coating in any paper, fabric and/or film coating application process unless;

    (i) The coating contains less than 265 grams of VOC per liter as applied, excluding water and excluding exempt compounds; or

    (ii) The VOC emissions from coating application operations are controlled by an emission control system with the combined collection and abatement efficiency of at least 90% on a mass basis at all times during the operation.

    (iii) Containers and mixing tanks for VOC containing materials are free from liquid leaks and are covered except when adding or removing materials, cleaning, or when the container is empty.

    (iv) Any cleaning of equipment involved in paper, fabric and/or film operations using VOC containing materials is performed according to the following requirements:

      (A) The cleaning material contains no more than 200 grams of VOC per liter; or

      (B) A system is used that totally encloses the component parts being cleaned during the washing, rinsing, and draining processes, or

      (C) The cleaning solvent is transferred through the application equipment, without exposure to air, into a container which has in place an apparatus or cover which completely covers the container and has no visible holes, breaks, openings or separations between adjoining components of the container or container cover.

  2. Rule 66 shall not apply to any paper, fabric and/or film coating operation which is subject to and in compliance with Section (d) of this rule.

  3. A person shall not sell, offer for sale, or apply any coating or cleaning solvent for use in paper, fabric and/or film coating operations that, after October 16, 1990, was newly formulated to contain or reformulated to increase the content of methylene chloride, trichlorofluoromethane (CFC-11), dichlorodifluoromethane (CFC-12), trichlorotrifluoroethane (CFC-113), dichlorotetrafluoroethane (CFC-114) or chloropentafluoroethane (CFC-115).

  4. After October 16, 1990, a person shall not manufacture, sell, offer for sale, or supply any coating or cleaning material for use in paper, fabric and/or film coating operations unless coating or cleaning material container displays the content of methylene chloride, trichlorofluoromethane (CFC-11), dichlorodifluoromethane (CFC-12), trichlorotrifluoroethane (CFC-113), dichlorotetrafluoroethane (CFC-114) or chloropentafluoroethane (CFC-115).

(e) recordkeeping

Any person subject to this rule shall maintain records of operations containing the following:

  1. A current list of coatings and VOCs in use which provides all of the coating and VOC data necessary to evaluate compliance; and

  2. Daily records showing the types and amounts of each coating and VOC content of each coating used; and

  3. Daily records showing the types and amounts of cleaning materials and VOC content of each cleaning material used.

  4. Maintain records of the content of methylene chloride, trichlorofluoromethane (CFC-11), dichlorodifluoromethane (CFC-12), trichlorotrifluoroethane (CFC-113), dichloroetrafluoroethane (CFC-114) and chloropentafluoroethane (CFC-115) in any coating material or cleaning material used.

Such records shall be retained for at least three years, and shall be made available to the District immediately upon request.

(f) test methods

Measurements of VOC subject to Subsections (d)(1)(i) of this rule shall be conducted and reported in accordance with EPA Test Method 24 (40 CFR 60, Appendix A) as it exists on October 16, 1990.

Calculations of the VOC content of coatings less water and less exempt compounds shall be performed in accordance with ASTM Standard Practice D 3960-87 for determining VOC content of paints and related coatings.

Measurements of the VOC content subject to Subsection (d)(1)(iv) of this rule shall be conducted in accordance with the most recent revisions of ASTM Test Methods D 4457-85 and D 3792-86.

Measurements of VOC content subject to Subsection (d)(1)(ii) of this rule shall be conducted and reported in accordance with EPA Guidelines for Capture Efficiency Determination, with EPA Test Methods 18 and 25 (40 CFR 60, Appendix A) as it exists on October 16, 1990.

(g) COMPLIANCE SCHEDULE

Any person conducting operations subject to this rule prior to October 16, 1990 that does not have an approved air pollution control system capable of complying with Subsection (d)(1)(ii) shall conform to the following increments of progress.

  1. By February 1, 1991, submit to the Air Pollution Control Officer applications for Authority to Construct and Permit to Operate an air pollution control system providing the emission reduction specified in Subsection (d)(1)(ii).

  2. By May 31, 1991, issue purchase orders for the basic VOC control device and other long delivery time components necessary to comply with Subsection (d)(1)(ii).

  3. By December 31, 1991, be in compliance with Subsection (d)(1)(ii).