SANTA BARBARA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 339 - MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS
(Adopted 11/5/1991, Revised 5/17/1994, 12/15/1994 and 4/17/1997)

A. Applicability

This rule applies to any person who sells, specifies the use of, offers for sale or applies coatings for the purpose of finishing or refinishing motor vehicles, mobile equipment and their exterior parts and components.

B. Exemptions

1. The requirements of this rule shall not apply to:
a. Original Equipment Manufacturer (OEM) coatings applied at manufacturing or assembly plants which are subject to Rule 330, Surface Coating of Metal Parts and Products or subject to the RACT requirements of the CTG EPA-450/2-77-008 "Control of Volatile Organic Emissions from Existing Stationary Sources" - (Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks).

b. Coating operations employing hand-held non-refillable aerosol cans, 18 ounces or less, provided the area to be painted does not exceed nine (9) square feet per vehicle to repair minor surface damage and imperfections.

2. With prior written approval of the Control Officer, the provisions of D.2 shall not apply where coatings are applied to a vehicle(s) which, due to shape or size, cannot reasonably be contained in a spray booth. To qualify for this exemption a person shall comply with the following requirements:
a. A written petition must be submitted on a case by case basis to the Control Officer stating the vehicle(s) to be coated, the size of the spray booth, the physical size of the vehicle(s) (i.e. length, width, and height), number of vehicle(s) to be coated, time required to paint vehicle(s), estimated volume of coating used, the date in which the vehicle or mobile equipment is to be coated, and the ROC content of each coating used; and

b. The petition must be submitted ten (10) calendar days prior to surface coating a motor vehicle or mobile equipment outside a spray booth. The Control Officer shall provide a written determination to the requester within five (5) calendar days of the proposed surface coating of the motor vehicle or mobile equipment.

c. The Control Officer may grant written approval for a specified time period, not to exceed one year.

3. The provisions of Section D.2 shall not apply to the following:
a. a motor vehicle engine compartment and mating assemblies of engine and suspension components where such components are replaced in the engine compartment.

b. the application of any undercoat which contains no lead or chromium compounds and is limited to one major panel per vehicle, or equivalent area, not to exceed an aggregate of 16 square feet per vehicle.

4. The provisions of Sections D.2 through D.12 and Sections E, F, and G shall not apply to the following:
a. painting of no more than one vehicle per year, by the registered owner of the vehicle being painted, provided that the surface coating being used does not contain lead or chromium compounds;

b. the application of touch-up coatings;

c. lettering and striping applied using hand application methods.

C. Definitions:

1. "Antiglare/Safety Coating" means a coating which does not reflect light.

2. "Camouflage Coating" means a coating applied on military motor vehicles to conceal such vehicles from detection.

3. "Catalyst" means a substance whose presence affects the rate of reaction between chemical compounds.

4. "Coating" means a material which is converted to a solid protective, decorative, or functional adherent film after application as a thin layer.

5. "Color Match" means the ability of a repair coating to blend into or match an existing coating so that color differentiation is not visible.

6. "Diluent" means a compound which is used to thin or reduce a coating. See definition for thinner or reducer.

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

8. "Exempt Compounds" means those compounds listed as exceptions in the definition for Reactive Organic Compounds in Rule 102. (Note: These compounds are under review and may be subject to control at a later date.)

9. "Extreme Performance Coating" means a coating applied to a Group II vehicle or mobile equipment which during intended use is exposed to any of the following conditions:

a. Chronic exposure to corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical mixtures or solutions,

b. Repeated exposure to temperatures in excess of 250 F.

c. Repeated heavy abrasion, including mechanical wear and repeated scrubbing with industrial grade solvents, cleansers or scouring agents.

d. Exterior exposure of steel and non-ferrous metal structures.

10. "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 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.

11. "Grams of ROC per Liter of Material" means the weight of ROC per volume of material, which contains no solids, and can be calculated by the following equation:

Where:

W_s = Weight of volatile compounds 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.

12. "Ground Support Vehicles" means vehicles used for support of aircraft activities at airports.

13. "Group I Vehicles" means passenger cars, light and medium-sized trucks and vans, large/heavy duty truck cabs and chassis, and motorcycles.

14. "Group II Vehicles and Mobile Equipment" means public transit buses and mobile equipment.

15. "Hand Application Methods" means the application of coatings by one of the following methods: air brush, paint brushes, hand rollers, caulking guns, trowels, spatulas, syringe daubers, rags, and sponges.

16. "High-Volume Low Pressure (HVLP) Spray" means spray equipment used to apply coatings by means of a high volume of air delivered at pressures between 0.1 and 10 psig air pressure, measured at the cap.

17. "Highway or Roadway" means a way or place of whatever nature, publicly maintained and open to the public for purposes of vehicular travel. Highway or roadway includes street.

18. "Lacquer" means a clear or pigmented coating formulated with nitrocellulose or synthetic resin to dry by evaporation without a chemical reaction and to provide a quick-drying, solid protective film.

19. "Large/Heavy Duty Truck or Van" means a truck having a manufacturer's gross vehicle weight (GVW) rating greater than 10,000 lbs.

20. "Light and Medium Duty Truck and Van" means a truck having a manufacturers GVW rating less than 10,000 lbs.

21. "Metallic/Iridescent Topcoat" means any coating which contains a minimum of 5 grams/liter of metal, as applied, where the coating has a metallic or iridescent appearance when cured or individual particles having such an appearance are visible in the cured coating.

22. "Mobile Equipment" means any equipment which can be drawn or is capable of being driven on a roadway, including but not limited to: truck bodies, truck trailers, utility bodies, camper shells, mobile cranes, all-terrain vehicles, bulldozers, concrete mixers, earth moving equipment, street cleaners, golf carts, implements of husbandry, and miscellaneous hauling or ground support equipment used inside and around airports, docks, depots, construction equipment, and industrial and commercial plants.

23. "Motorcycle" means any motorcycle as defined in California Vehicle Code § 400 which is defined as a motor vehicle other than a tractor having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground and weighing less than 1500 pounds, except that four wheels may be in contact with the ground when two of the wheels are a functional part of a sidecar.

24. "Multi-Stage Topcoat System" means a topcoat system composed of either a basecoat/clearcoat, a basecoat/midcoat/clearcoat, or a groundcoat/basecoat/midcoat/clearcoat.

The ROC content of a basecoat/clearcoat coating system shall be calculated according to the following formula:

 



The ROC content of a 3 Stage coating system shall be calculated according to the following formula:
The ROC content of a 4 Stage coating system shall be calculated according to the following formula:
Where:

ROC Total is the sum of the ROC content, as applied, and used to determine compliance with the standards in section D.1.

ROCbc is the ROC content, as applied, of a pigmented basecoat.

2ROCcc is two times the ROC content, as applied, of a transparent clearcoat.

ROCmc is the ROC content, as applied, of a translucent midcoat.

ROCgc is the ROC content, as applied, of a pigmented groundcoat or tinted primer sealer.

25. "Passenger Car" means a passenger car as defined in California Vehicle Code § 465, which is defined as any motor vehicle designed primarily for transportation of persons and having a design capacity of 12 persons or less.

26. "Precoat" means a coating applied to bare metal to deactivate the metal surface for corrosion resistance. For compliance with this rule, any precoat must be followed by a water-based primer coat.

27. "Pretreatment Wash Primer" means any coating which contains a minimum of 0.5% by weight of acid for etching bare metal to enhance corrosion resistance and adhesion.

28. "Primer" means any coating applied prior to the application of a topcoat for the purpose of corrosion resistance and adhesion of the topcoat.

29. "Primer Sealer" means any coating applied prior to the application of a topcoat for the purpose of corrosion resistance, adhesion of the topcoat, color uniformity, and to promote the ability of an undercoat to resist penetration by the topcoat.

30. "Primer Surfacer" means any coating applied prior to the application of a topcoat for the purpose of corrosion resistance, adhesion of the topcoat, and which promotes a uniform surface by filling in surface imperfections.

31. "Reducer" means the use of a volatile liquid to reduce the viscosity of a coating. This liquid may contain solvents, diluents or mixtures of both.

32. "Retarder" shall be considered to be a reducer or thinner for purposes of this rule.

33. "Refinishing" means any coating of vehicles, their exterior parts or components, or mobile equipment, including partial body collision repairs, for the purpose of protection or beautification and which is subsequent to the original coating applied at an Original Equipment Manufacturer (OEM) plant coating assembly line.

34. "Specialty Coatings" means coatings which are necessary due to unusual job performance including finish blenders, elastomeric materials, gloss flatteners, bright metal trim repair, and anti-glare/safety coatings.

35. "Spot/Panel Repair" means the nonassembly line process of repairing and restoring a portion of a motor vehicle to predamaged condition.

36. "Spray Booth" as defined in the Uniform Fire Code §9.121, means a power ventilated structure of varying dimensions and construction provided to enclose or accommodate a spraying operation and to confine and limit the escape of spray vapor and residue and to exhaust it safely.

37. "Surface Preparation" means the use of ROC containing solvents applied with cloth, sponge or other medium for the purpose of removing dust, grease and other contaminants from a surface prior to application of a coating.

38. "Thinner" means a volatile liquid used to lower the solid concentration or the viscosity of a coating.

39. "Topcoat" means a coating applied over a primer or an original equipment manufacturer finish for appearance, identification or protection purposes. Multi-Stage coating systems shall be considered topcoats.

40. "Touch-up Coating" means a coating applied by brush, air brush, detail HVLP spray equipment or hand-held, non-refillable aerosol cans to repair minor surface damage and imperfections.

41. "Transfer Efficiency" means the ratio of the amount by weight of coating which is deposited on the object to be coated to the amount by weight of coating sprayed, usually expressed as a percentage.

42. "Undercoat" means any pretreatment wash primer, precoat, primer, primer surfacer or primer sealer.

43. "Vehicle" means a device by which any person or property may be propelled, moved or drawn upon a highway, excepting a device moved exclusively by human power or used exclusively upon stationary rails or tracks (CVC §670).

D. Requirements

1. Effective on the dates specified below, a person shall not sell, offer for sale or apply any coating to Group I and II motor vehicles, mobile equipment and their exterior parts and components, with a reactive organic compound (ROC) content, expressed as grams of ROC per liter of coatings, less water and exempt compounds, applied in excess of the limits contained in D.1.a or D.1.b below:
a. Group I Motor Vehicles, their exterior parts and components, or Group II vehicles where color match is required:

b. Group II Motor Vehicles and Mobile Equipment, their exterior parts and components, where color match is not required:

2. All surface coatings which are subject to this Rule shall be applied in a permitted, properly maintained, and operating spray booth.

3. Extreme Performance Coating Petition: Any person, prior to the use of an extreme performance coating in any coating operation subject to this Rule shall comply with the following requirements:

a. A petition shall be submitted to the Control Officer stating the performance requirements, volume of coating to be used which ROC content of the coating proposed to be used and any other information that the Control Officer deems necessary. The petition must demonstrate to the satisfaction of the Control Officer that no other coatings are available which have the appropriate ROC limit which is specified within this Rule.

b. The Control Officer may grant written approval for a specified time period, not to exceed one year.

c. If the Control Officer grants approval, such approval shall contain volume and ROC limit conditions.

4. Specialty Coatings: A person shall not use any specialty coating with a ROC content in excess of 840 g/l (7.0 lbs/gal), excluding water and exempt solvents. The application of topcoats with a specialty coating used as an additive shall be subject to the topcoat limits in D.1.a. and D.1.b.

5. Sources may elect to use add-on exhaust control equipment to achieve compliance with the provisions of Section D.1.a or D.1.b provided that the control equipment meets the requirements of 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 (ATC) from the District and a Permit to Operate (PTO) in accordance with District Rules.

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.

6. Compliance Statement Requirement: The manufacturer of coatings subject to this Rule shall include a designation of ROC as applied, including coating components, expressed in grams per liter or pounds per gallon, excluding water and exempt compounds, on container labeling or product data specification sheets.

7. Transfer Efficiency: A person shall not apply any coating to any Group I and/or II vehicles and mobile equipment or their parts and components unless one of the following methods is used:

a. Electrostatic application equipment, operated in accordance with the manufacturer's recommendations;

b. High Volume Low Pressure (HVLP) spray equipment, operated in accordance with the manufacturer's recommendations;

c. Dip coat application;

d. Flow coat application;

e. Hand application methods;

f. Any other coating application that achieves at least 65 percent transfer efficiency as demonstrated by the test method specified in Section E.5.

8. Surface Preparation and Cleanup: Any person using ROC-containing material for surface preparation and cleanup shall comply with the following requirements:
a. A person shall use closed containers, that are nonabsorbent and fire resistant, for the storage or disposal of ROC-containing cloth or paper used for surface preparation and cleanup.

b. A person shall not use ROC-containing materials for spray equipment cleanup unless an enclosed system is used for cleaning. The system used must totally enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining procedures. Pre-rinse and final-rinse of the internal components of spray guns using ROC-containing materials may be conducted into a sealable container, provided that a continuous, fluid (non-atomized) stream is used. Alternatively, equipment may be used for clean up which has been demonstrated to the satisfaction of the Control Officer to be as effective as any of the equipment described above in minimizing the loss of ROC-containing materials to the atmosphere according to the South Coast Air Quality Management District General Test Method for Determining Solvent Losses From Spray Gun Cleaning Systems, dated October 3, 1989.

c. A person shall not use ROC-containing materials for surface preparation which have a ROC content of more than 200 grams of ROC per liter of material (1.67 lb/gal.).

9. Precoat Limitation: A person shall not use precoat in excess of 25%, by volume, of the amount of primer/primer surfacer used on a monthly basis. Compliance with this provision shall be based upon purchase records and/or daily coating records.

10. 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.

11. 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 exterior 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 exterior part or component at any physical location within the District.

12. Prohibition of Sale: Except for sources that comply with Section D.5, a person shall not offer for sale or sell within the District any coating if such product is prohibited by any of the provisions 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.

13. Any coating subject to specified requirements in this Rule shall be exempt from the requirements of Rule 317 and Rule 322. Any coatings exempt from this Rule shall comply with all other applicable District Rules and Regulations.

E. Test Methods

1. ROC content of a coating shall be determined using EPA Reference Method 24 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.5.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.5.b shall be based on EPA Guidelines for Developing Capture Efficiency Protocols from the Federal Register Part 55 FR 26865, June 29, 1990.

4. Acid content in pretreatment wash primers shall be determined by ASTM D1613-81.

5. Compliance with Section D.7.f shall be determined using South Coast Air Quality Management District Method "Spray Equipment Transfer Efficiency Test Procedure for Equipment User", May 24, 1989.

6. Iridescent particles in metallic iridescent topcoats shall be determined pursuant to the spectrographic method contained in Section 3, Method 311 of the South Coast Air Quality Management District "Laboratory Method of Analysis for Enforcement Samples" manual, in effect on November 5, 1991 or an equivalent method approved by the Control Officer, ARB and EPA.

F. Recordkeeping

1. Operators of facilities subject to this Rule shall maintain a current listing of all as-applied 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 (such as Group I or Group II, or precoat must be applied to bare metal and followed with a compliant primer);

d. specific mixing instructions;

e. maximum ROC content of coatings 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, shall be available for review on site.

3. Purchase records identifying the type or name and the volume of material purchased for each ROC containing material shall be available for inspection by the Control Officer or a designated representative upon request.

4. A record of the total facility ROC emissions shall be maintained on a monthly basis. These records shall be summarized for the previous calendar year and submitted to the District by March 1.

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

6. All records shall be retained and available for inspection by the Control Officer or a designated representative for the previous 36 month period.