SANTA BARBARA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 337 - SURFACE COATING OF AIRCRAFT OR AEROSPACE VEHICLE PARTS AND PRODUCTS
(Adopted 7/10/1990, revised 7/24/1990 and 10/20/1994)

A. Applicability

This rule is applicable to any person who manufactures, applies or specifies the use of surface coatings for aircraft or aerospace vehicle parts and products.

B. Exemptions

1. The provisions of Section D shall not apply to any coatings with separate formulations used in volumes of less than 20 gallons in any calendar year provided that the total volume of non-complying coatings used at a stationary source does not exceed 200 gallons annually. Coatings used for operations that are exempt per Sections B.2 and B.3 shall not be included in calculating the volume of coatings used under this exemption. Any person claiming this exemption shall maintain on a monthly basis an annual running total of the volume of each separate formulation of coating used under this exemption. These coatings shall be subject to the records required by Section H.

2. The provisions of Section E. shall not apply to touch-up and repair.

3. The provisions of this rule shall not apply to coatings supplied in non-refillable aerosol containers with capacities of 18 ounces or less.

4. Any coating subject to the requirements of this rule shall be exempt from the requirements of Rule 317 and Rule 322. Any coating exempt from this rule shall comply with all other applicable District Rules.

C. Definitions

See Rule 102 for definitions not restricted to interpretation of this rule. Definitions specific to this rule are listed below.

1. "Adhesive Bonding Primer" means a coating applied in a very thin film to aircraft or aerospace parts or products for the primary purpose of providing a primer for a subsequent coat of structural adhesive.

2. "Aircraft or Aerospace Vehicle" means a fabricated part, assembly of parts or completed unit of any aircraft, helicopter, missile or space vehicle.

3. "Detailing or Touch-up Guns" are small air spray equipment, including air brushes, that operate at no greater than 5 CFM air flow and no greater than 50 pounds per square inch gauge (Psig) air pressure and are used to coat small products or portions of products.

4. "Interior Topcoat" means a topcoat used in habitable interior spaces of aircraft.

5. "Electric/Radiation Effect Coatings" means an electrically conductive or insulative coating, or coatings used on radar and antennae enclosures.

6. "Electrostatic Application" means using a sufficient charging of atomized paint droplets to cause deposition by electrostatic attraction. This application requires a minimum 60kV power supply.

7. "Exempt Organic Compounds" means those compounds listed as exceptions in the definition of "Reactive Organic Compounds" in Rule 102.

8. "Extreme Performance Interior Topcoat" means a topcoat used in interior spaces of aircraft areas requiring a fluid, stain or nicotine barrier.

9. "Fire Insulation Coating" means a coating used to provide a layer of insulation in the event of an aircraft or engine fire.

10. "Fuel Tank Coating" means a coating applied to the interior of a fuel tank or to fuel wetted areas of aircraft to protect it from corrosion.

11. "Grams of ROC per Liter of Coating Less Water and Less Exempt Compounds" means the weight of ROC per combined volume of ROC and coating solids and can be calculated by the following equation:

Where:

W_s = Weight of volatile compounds (including water) in grams.

W_w = Weight of water in grams.

W_es = Weight of exempt organic compounds in grams.

V_m = Volume of material in liters.

V_w = Volume of water in liters.

V_es = Volume of exempt organic compounds in liters.

12. "Hand Application Method" means the application of a surface coating by manually held non-mechanically operated equipment. Such equipment includes paint brush, hand-roller, trowel, spatula, dauber, rag or sponge.

13. "High Temperature Coating" means a coating that, during normal use, must withstand temperatures in excess of 350 °F.

14. "High Volume Low Pressure Spraying" means using spray equipment with air pressure between 0.1 and 10.0 psi and air volume greater than 15.5 cfm per spray gun.

15. "Maskant-Chemical Processing" means a coating applied directly to a part to protect surface areas when chemical milling, anodizing, aging, bonding, plating, etching and/or performing other chemical operations on the surface of the part.

16. "Pretreatment Wash Primer" means a coating which contains a small quantity of acid for surface etching and is applied directly to surfaces to provide corrosion resistance, adhesion and ease of stripping.

17. "Primer" means a coating applied directly to a part for purposes of corrosion prevention, protection from the environment, functional fluid resistance and/or adhesion of subsequent coatings.

18. "Repair" means recoating of previously coated product due to damage to the coating following normal painting operations.

19. "Sealant" means a coating applied for the purpose of filling voids and providing a barrier against penetration of water, fuel or other fluids or vapors.

20. "Sealant Bonding Primer" means a coating applied in a very thin film to a part or product for the purpose of providing a primer for a subsequent coat of silicone sealant.

21. "Self Priming Topcoat" means a coating applied directly to a part or product that is not subsequently overcoated.

22. "Space Vehicle Coating" means a coating applied to vehicles designed to travel beyond the earth's atmosphere.

23. "Stripper" means a precursor organic compound applied to remove temporary coating, maskant for chemical processing, paint or residue.

24. "Structural Adhesive" means a coating which is applied for the purpose of bonding structural components together.

25. " Temporary Protective Coating" means a coating applied to a part to protect it from mechanical and environmental damage during manufacturing.

26. "Topcoat" means a coating applied over primer or intermediary coating for purposes such as appearance, identification or protection.

27. "Touch up" means that portion of the coating operation which is separate from the main coating process but necessary to cover minor imperfections or to achieve coverage as required.

28. "Transfer Efficiency" means the ratio of the weight of coating solids adhering to the object being coated to the weight of coating solids used in the application process, expressed as a percentage.

29. "Wing Coating" means a corrosion-resistant coating that is resilient enough to withstand the flexing of the aircraft wings.

D. Requirements - ROC Limits

1. A person shall not apply any coating or specify the use of any coating which, as applied, emits or may emit reactive organic compounds into the atmosphere in excess of the limits shown in the table below. These limits are expressed in grams per liter or pounds per gallon of coating less water and exempt organic compounds:

 

2. A person shall not apply any stripper or specify the use of any stripper unless it complies with one or both of the following:

a. The stripper contains less than 400 grams/liter of ROC.

b. The stripper has a true vapor pressure of less than 10 mm Hg at actual usage temperature.

3. Sources may elect to use add-on exhaust control equipment to achieve compliance with the provisions of Section D, provided that the control equipment meets the requirements of sections a. and b. below. Such control equipment must be approved in advance by the Control Officer. Any person choosing to install such control equipment shall obtain an Authority to Construct from the District prior to installation.
a. The control device shall reduce emissions from an emission collection system by at least 95 percent by weight.

b. The emission collection system which collects and transports emissions to an air pollution control device shall collect at least 90 percent by weight of the emissions generated by the sources of emissions.

E. Requirements - Application Equipment

A person shall not apply coatings subject to the provisions of this rule except by using properly operated equipment and by:

1. Electrostatic application, or

2. Flow coat application, or

3. Dip coat application, or

4. High volume, low pressure spraying (HVLP), or

5. Electrodeposition, or

6. Hand application methods, or

7. Detailing or touch-up guns, or

8. Any other coating application method that achieves a transfer efficiency of at least 65 percent as demonstrated by the test method specified in Section I.4.

F. Requirements - Closed Containers

All ROC-containing materials, used or unused, including but not limited to surface coatings, thinners, cleanup solvents, or surface preparation materials shall be stored in closed containers and opened only during extraction or introduction of material for mixing, use or storage.

G. Requirements - Labeling

1. Each container of any coating subject to this rule shall display the date on which the contents were manufactured or a code indicating the date of manufacture. Each manufacturer of such coatings shall file with the Air Pollution Control Officer and the Executive Officer of the California Air Resources Board an explanation of each code.

2. Each container of any coating subject to this rule shall display a statement of the manufacturer's recommendation regarding thinning of the coating. This recommendation shall not apply to the thinning of coatings with water. The recommendation shall specify that the coating is to be employed without thinning or diluting under normal environmental and application conditions unless any thinning recommended on the label for normal environmental and application conditions does not cause a coating to exceed its applicable standard.

3. Each container of any coating subject to this rule shall display the maximum ROC content of the coating, as applied, and after any thinning as recommended by the manufacturer. ROC content shall be displayed as g/l or lb/gal of coating less water and exempt organic compounds. The VOC content may be displayed instead of the ROC content as long as the manufacturer's definition of VOC is consistent with the definition of ROC contained in District Rule 102. ROC content displayed may be calculated using product formulation data, or may be determined using the test method in Section I.

H. Recordkeeping

Persons subject to this rule shall comply with the following requirements.

1. Maintain a current listing of all ROC-containing materials in use at their facility. This listing shall include:
a. material name and manufacturer identification;

b. application method;

c. material type and specific use instructions;

d. specific mixing ratio;

e. maximum ROC content of coating less water and less exempt compounds as applied (including thinning solvents).

2. Current coating manufacturer specification sheets, Material Safety Data Sheets or current air quality data sheets, which list the ROC content of each material in use at their facility, shall be available for review on site.

3. Maintain purchase records identifying the type or name and the volume of material purchased for each ROC-containing material.

4. Maintain on a monthly basis a record of the volume, ROC content, and resulting ROC emissions of each ROC-containing material used. These records shall be summarized for each calendar year and submitted to the District by March 1 of the following year.

5. Operators of facilities that use non-compliant coating materials with compliance achieved through the operation of emission control equipment shall maintain daily records of key operating and maintenance procedures which demonstrate continuous operation and compliance of the emission control device during periods of emission producing activities.

6. All records required by this rule shall be retained and available for inspection by the Control Officer or designated representative upon request for the previous 36 month period.

I. Test Methods

1. ROC content of a coating shall be determined using EPA Reference Method 24, its constituent methods or an equivalent method approved by the Control Officer, ARB and EPA. The determination of exempt compounds shall be performed in accordance with ASTM D 4457-85.

2. Compliance with Section D.3.a shall be determined by using ARB Method 100 or EPA Method 25 or a method determined to be equivalent and approved by the Control Officer, ARB, and EPA.

3. Compliance with Section D.3.b shall be based on EPA Guidelines for Developing Capture Efficiency Protocols from 55 FR 26865, June 29, 1990.

4. Compliance with Section E.8 shall be determined using South Coast Air Quality Management District Method "Spray Equipment Transfer Efficiency Test Procedure of Equipment User", May 24, 1989.

5. Compliance with Section D.2 shall be determined using ASTM D 2879-86, manufacturer's specified vapor pressure, or an accepted scientific reference.