IMPERIAL COUNTY AIR POLLUTION CONTROL DISTRICT
RULE 427 AUTOMOTIVE REFINISHING OPERATIONS
The purpose of this Rule is to limit the emission of Volatile Organic Compounds from the Finishing or Refinishing of Motor Vehicles, Mobile Equipment and their parts and components.
This Rule applies to any facility engaged in the assembly of or Refinishing of Group I (buses and Mobile Equipment) and Group II (passenger cars, Large/Heavy Duty Truck cabs and chassis, Light and Medium Duty Trucks and Vans, and motorcycles) vehicles, when the process(es) utilize any of the products specified in subsection C.1.a of this Rule.
The following terms used in this Rule are defined in Rule 101 - Definitions:
Additive; Anti-Glare/Safety Coating; Camouflage Coating; Catalyst; Coating; Color Match; Electrostatic Application; Extreme Performance Coating; Finish; Graphic Design Application; Group I Vehicles; Group II Vehicles and Equipment; High-Volume, Low-Pressure (HVLP) Spray; Large/Heavy Duty Trucks; Light and Medium Duty Trucks and Vans; Metallic Topcoat; Mobile Equipment; Multicolored Topcoat; Pretreatment Wash Primer; Primer; Primer Sealer; Primer Surfacer; Reducer; Refinishing; Specialty Coatings; Spot/Panel Repair; Surface Preparation Solvent; Topcoat; Touch-up Coating; Transfer Efficiency.
For the purpose of this Rule the following definitions shall apply:
GRAMS OF VOC PER LITER OF Coating LESS WATER AND LESS EXEMPT COMPOUNDS: the weight of VOC per combined volume of VOC and Coating solids is calculated by the following equation:
GVOC= WS - WW - WES
VM - Vw - Ves
GVOC = Grams VOC/L of Coating less water and Exempt Compounds
WS = weight of volatile compounds in grams
WW = weight of water in grams
WES = weight of Exempt Compounds in grams
VM = volume of material in liters
VW = volume of water in liters
VES = volume of Exempt Compounds in liters
MULTI-STAGE TOPCOAT SYSTEM: a Topcoat system composed of either a basecoat/clearcoat, a basecoat/midcoat/clearcoat, or a groundcoat/basecoat/midcoat/clearcoat. The VOC content of a multi-stage Topcoat system shall be determined according to the following formulas:
For a basecoat/clearcoat system:
VOCbc + 2VOCcc
VOCMS = 3
For a 3 Stage Coating system:
VOCbc + VOCmc + 2VOCcc
VOCMS = 4
For a 4 Stage Coating system:
VOCMS = VOCgc + VOCbc + VOCmc + 2VOCcc
VOCMS is the average of the VOC content, as applied, and used to determine compliance with the standards in subsection C.1.a.1.
VOCgc is the VOC content, as applied of a pigmented groundcoat or tinted Primer Sealer.
VOCbc is the VOC content, as applied, of a pigmented basecoat.
VOCmc is the VOC content, as applied, of a translucent midcoat.
2VOCcc is two times the VOC content, as applied, of a transparent clearcoat.
VOLATILE ORGANIC COMPOUND is any compound containing at least one atom of carbon, except for the following compounds and solvents: methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, 1, 1,1-trichloroethane, methylene chloride, trichlorofluoromethane (CFC-11), dichlorodifluoromethane (CFC-12), chlorodifluoromethane (HCFC-22), trifluoromethane, (HFC-23), 1,1,12-trichloro-21,2,2-trifluoroethane (CFC-113), 1,2-dichloro- 1,1,2,2-tetrafluoroethane (CFC-114), chloropentafluoroethane (CFC-115), 2,2-dichloro-1.1.1-trifluoroethane (HCFC-123), 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124), pentafluorethane (HFC-125), 1,1,2,2-tetrafluoroethane (HFC-134), 1,1,1,2-tetrafluoroethane (HFC-134a), 1,1-dichloro-1-fluoroethane (HCFC-141b), 1-chloro-1,1-difluoroethane (HCFC-142b), 1,1,1-trifluoroethane (HFC-143a), 1,1-difluoroethane (HFC-152a), and the following four classes of perfluorocarbon (PFC) compounds:
1. cyclic, branched, or linear, completely fluorinated alkanes,
2. cyclic, branched, or linear, completely fluorinated ethers with no unsaturations,
3. cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations, and
4. saturated perfluorocarbons containing sulfur with sulfur bonds only to carbon and fluorine.
C.1.a Any Person who applies Coating to Group I or II vehicles, Mobile Equipment, their parts and components, shall comply with subsections C.1.a.1 or C.1.a.2 below:
C.1.a.1 Group I Vehicles and Mobile Equipment: Any Person shall not Finish or refinish Group I Vehicles and Equipment or their parts and components where Color Match is not required, using any Coating with a VOC content in excess of the following limits, expressed as grams of VOC per liter (or pounds per gallon) of Coating, as applied excluding water and exempt solvents, unless emissions of VOC to the Atmosphere are controlled by air pollution abatement Equipment with combined Capture Efficiency and Control Efficiency of the abatement device of at least 85 percent, and which has been approved in writing by the Air Pollution Control Officer:
Pretreatment Wash Primer 780 g/L (6.5 lbs/gal)
Primer 420 g/L (3.5 lbs/gal)
Primer Sealer 420 g/L (3.5 lbs/gal)
Primer Surfacer 420 g/L (3.5 lbs/gal)
Metallic Topcoat 420 g/L (3.5 lbs/gal)
Extreme Performance 420 g/L (3.5 lbs/gal)
Multicolored 685 g/L (5.7 lbs/gal)
Camouflage Coating 420 g/L (3.5 lbs/gal)
All Other Topcoats 420 g/L (3.5 lbs/gal)
C.1.a.2 Group II Vehicles: Any Person shall not refinish Group II Vehicles, their parts and components, or Group I Vehicles and Mobile Equipment where Color Match is required, using any Coating with a VOC content in excess of the following limits, expressed as grams of VOC per liter (or pounds per gallon) of Coating as applied, excluding water and exempt solvents, unless emission of VOC to the Atmosphere are controlled by air pollution abatement Equipment with a combined Capture Efficiency and Control Efficiency of the abatement device efficiency of at least 85 percent, and which has been approved in writing by the Air Pollution Control Officer:
****insert table gif
Pretreatment Wash Primer 780 g/L (6.5 lbs/gal)
Primer/Primer Surfacer 420 g/L (3.5 lbs/gal)
Primer Sealer 420 g/L (3.5 lbs/gal)
Metallic Topcoat 520 g/L (4.3 lbs/gal)
Multistage Topcoat System 540 g/L (4.5 lbs/gal)
Multicolor 685 g/L (5.7 lbs/gal)
Multicolor Multistage 480 g/L (4.0 lbs/gal)
All Other Topcoats 420 g/L (3.5 lbs/gal)
Speciality Coating 840 g/L (7.0 lbs/gal)
C.2 Transfer Efficiency
C.2.a For all Coatings, any Person shall not apply any Coating to any Group I or II vehicles or Mobile Equipment or their parts and components unless one of the following methods is used:
C.2.a.1 Electrostatic Application Equipment, operated in accordance with the manufacturer's recommendations;
C.2.a.2 High Volume Low Pressure (HVLP) spray Equipment, operated in accordance with the manufacturer's recommendations;
C.2.a.3 Any other Coating application which has been demonstrated to the satisfaction of the Air Pollution Control Officer to be capable of achieving at least 65 percent Transfer Efficiency, as per section G.2.c, and for which written approval of the Air Pollution Control Officer has been obtained.
C.3 Prohibition of Specification
No Person shall solicit or require for use or specify the application of a Coating on a Group I or II vehicle, Mobile Equipment, or part or component thereof if such use or application results in a violation of the provisions of this Rule. The prohibition of this section shall apply to all written or oral contracts under the terms of which any Coating which is subject to the provisions of this Rule is to be applied to any Motor Vehicle, Mobile Equipment, or part or component at any physical location within the District.
C.4 Prohibition of Sale
No Person shall offer for sale or sell within the District any Coating that does not meet the VOC content limits as set forth in subsection C.1.a of this Rule. The prohibition of this section shall apply to the sale of any Coating which will be applied at any physical location within the District.
C.5 Compliance Statement Requirement
The manufacturer of Coatings subject to this Rule shall include a designation of VOC as supplied on data sheets; including Coating components, expressed in gram per liter or pounds per gallon, excluding water and exempt solvents.
C.6 Surface Preparation and Cleanup Solvent
The requirements of this section shall apply to any Person using solvent for surface preparation and cleanup.
C.6.a Any Person shall not use an organic compound(s), or mixture thereof, (excluding Exempt Compounds) for surface preparation with a VOC content in excess of 200 grams per liter (1.67 pounds per gallon) of material, as applied.
C.6.b Any Person shall use closed, non-absorbent containers for the storage or disposal of any applicator (including brushes, swabs, cloth or paper) used for solvent surface preparation and cleanup.
C.6.c Any Person shall store fresh or open solvent in closed containers.
C.6.d Any Person shall not use organic compounds for the cleanup of spray Equipment including paint lines unless an enclosed system is used for cleanup. The system shall enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining procedures. Equipment used shall minimize the evaporation of organic compounds to the Atmosphere.
C.7 Any Person shall not use any speciality Coating with a VOC content, as applied, in excess of 840 g/L (7.0 lbs/gal), excluding water and exempt solvents. Use of all speciality Coating except anAnti-Glare/Safety Coating glare/safety Coatings shall not exceed 5.0 percent of all Coating, applied, averaged on a monthly basis. The application of Topcoats with a Specialty Coating used as an Additive shall be subject to the Topcoat limits in subsections C.1.a.1 or C.1.a.2.
C.8. Any Person seeking to use an Extreme Performance Coating in any Coating operation which is subject to this Rule shall comply with the requirements of subsection E.1.a.
D.1 The provisions of this Rule shall not apply to:
D.1.a A facility which uses a total of less than one (1) gallon of Coating, including any VOC-containing materials added to the original Coating as supplied by the manufacturer, subject to this Rule, in any one day; or
D.1.b Surface Coating operations that emit not more than 3 pounds of VOC's per day and not more than 200 pounds of VOC's per calendar year.
D.1.c Noncommercial Motor Vehicle and Mobile Equipment Refinishing operations performed by any individual at his/her residence for the purpose of Finishing or Refinishing that individual's personal vehicles.
D.1.d Touch-Up Coatings.
D.1.e Graphic Design Applications.
D.1.f Coating applied using non-refillable hand-held aerosol spray containers.
D.1.g Body fillers.
D.1.h Bedliner Coatings.
D.2 The limits set forth in subsection C.1.a.1 and C.1.a.2 shall not apply to:
D.2.a automotive Refinishing operations which emit not more than 3 pounds of VOC per hour, before add-on controls; or
D.2.b automotive Refinishing operations which emit not more than 15 pounds of VOC per day, before add-on controls; or
D.2.c facilities that do not exceed 10 tons per year theoretical Potential Emissions. "Theoretical Potential Emissions" is defined as the greater of design capacity, or maximum production (based on 8760 hours/year) before add-on controls.
D.3 For the purposes of claiming an exemption pursuant to subsections D.2.a or D.2.b, hourly or daily emissions shall be considered from Date Of Adoption of Rule forward.
D.4 Once a facility exceed 3 pounds of VOC per hour, or 15 pounds of VOC per day, respectively, it will become and remain subject to the limits even if its emissions later fall below the applicability threshold.
D.5 Any facility or Person classified as exempt or claiming to be exempt under this section (D), shall meet the record keeping requirements of this Rule so as to be able to prove the exemption status.
E. Administrative Requirements
E.1 Extreme Performance Coating Petition:
Any Person seeking to use an Extreme Performance Coating in any Coating operation which is subject to the provisions of this Rule shall comply with the following requirements:
E.1.a A petition shall be submitted to the Air Pollution Control Officer stating the performance requirements, volume of Coating, and VOC level which is attainable. The petitioner must also, in a written statement, certify that after reasonable inquiry, to their knowledge, no other Coating(s) are available which will meet the requirements of subsection C.1.a of this Rule and of the specified performance requirements for a specific contract.
E1.b If the Air Pollution Control Officer grants written approval, such petition will be repeated on an annual basis.
E.1.c If the Air Pollution Control Officer grants written approval, such approval shall contain volume and VOC limit conditions.
E.1.d Records must be maintained as in Section F.1.
E.2 Rule 417 Applicability:
Any Coating, Coating operation, or facility which is exempt from all or a portion of the VOC limits of this Rule shall comply with the provisions of Rule 417.
F. Monitoring and Records
All Persons subject to this Rule and any Person claiming any exemption under subsection D.1 shall comply with the following requirements:
F.1 Maintain and have available during an inspection, a current list of Coating in use which provides all of the Coating data necessary to evaluate compliance, including the following information separately for both Group I and II vehicles , as applicable:
F.1.a Additive, Coating, Catalyst, and Reducer used.
F.1.b Mix ratio of components used
F.1.c VOC content of Coating as applied.
F.2 Maintain records on a daily basis including:
F.2.a Coating and mix ratio of components used in the Coating; and
F.2.b quantity of each Coating applied.
F.2.c Any Person/facility utilizing an add-on emission Control Device/system as a means of complying with provisions of this Rule shall also maintain records of key system operating and maintenance data for the purpose of demonstrating continuous compliance during periods of emission producing activities. The data shall be recorded in a manner a prescribed by the District.
F.3 The Person shall maintain records on a monthly basis showing the type and amount of solvent used for cleanup and surface preparation.
F.4 Such records shall be retained and available for inspection by the Air Pollution Control Officer for the previous 24 month period.
G. Test Methods
G.1 A violation of the limits contained in this Rule as determined by any one of these test methods shall constitute a violation of this Rule.
G.2 The following specified test methods shall be used to determine compliance with the provisions of this Rule.
G.2.a Analysis of Samples - VOC Determination:
Samples of Volatile Organic Compounds (less Exempt Compounds) as specified in Sections C.1.a.1 to C.1.a.2 shall be analyzed as prescribed by EPA Reference Method 24 for VOC content (without correction for Exempt Compounds) and ASTM Test Method D4457-85, or CARB Method 432 for determination of emissions of Exempt Compounds. Perfluorocarbon compounds shall be assumed to be absent from a product or process unless a manufacturer or facility operator identifies the specific individual compounds (from the broad classes of perfluorocarbon compounds) and the amount present in the product or process and provides a validated test method which can be used to quantify the specific compounds.
G.2.b Determination of Emissions:
Emissions of Volatile Organic Compounds as specified in Sections C.1.a.1 or C.1.a.2 shall be measured as prescribed by EPA Reference Method 25 for determining VOC emissions and Control Device efficiency, in combination with the methods prescribed in U.S. EPA document Guidelines for Determining Capture Efficiency, dated January 9, 1995.
G.2.c Determination of Transfer Efficiency:
Transfer Efficiency as required by Section C.2.a.3 shall be determined by procedures as prescribed in the SCAQMD document "South Coast Air Quality Management District Spray Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1998".
G.2.d Determination of Percentage of Metal in Metallic Coatings:
Determinations shall be made using SCAQMD Method 311-91, "Determination of Percent Metal in Metallic Coatings by Spectrographic Method", as found in the SCAQMD document Laboratory Methods Of Analysis For Enforcement Samples, The June 1991 edition.
G.2.e Acidity in volatile Solvents and in Coating Compounds:
Determination of acid strength shall be made using ASTM Test method D1613-85.
G.2.f Determination of Exempt Compounds Content:
Determination of the content of Exempt Compounds in Coating or solvents or any diluents shall be by ASTM Test Method D4457-85.