SAN DIEGO COUNTY AIR POLLUTION CONTROL DISTRICT
RULE 67.9 - AEROSPACE COATING OPERATIONS
(Effective 8/24/83; Rev. Effective 4/30/97)
(a) APPLICABILITY
(b) EXEMPTIONS
(i) Touch-up coatings and stencil coatings.
(ii) A stationary source where not more than 50 gallons per consecutive 12-month period of aerospace coating is used. This amount does not include coatings specified in Subsections (b)(1)(i), (b)(1)(v) and (b)(1)(vi).
(iii) Coatings that are used in volumes of less than 200 gallons per consecutive 12-month period provided a total of not more than 200 gallons per consecutive 12-month period of all such non-compliant coatings are used at any stationary source. This amount shall not include coatings specified in Subsections (b)(1)(i), (b)(1)(iv), (b)(1)(v) and (b)(1)(vi).
(iv) Coatings used exclusively for purposes of research and development, including coatings applied to mock-ups and prototypes, provided not more than 50 gallons per consecutive 12-month period of all such non-compliant coatings are used at the stationary source.
(v) Coatings applied using non-refillable aerosol spray containers.
(vi) Prepreg composite materials.
It shall be the responsibility of any person claiming any of the above exemptions to maintain calendar month records of coating usage. Such records shall show the amount of each coating used in accordance with information required by Subsection (f)(1) of this rule. These records shall be retained on site for at least three years and shall be made available to the District upon request.
It shall be the responsibility of any person claiming exemptions (b)(3) or (b)(4) above to maintain calendar month usage records. Such records shall show the amount of each adhesive and sealant used in accordance with information required by Subsection (f)(1) of this rule. These records shall be retained on site for at least three years and shall be made available to the District upon request.
(c) DEFINITIONS
For the purposes of this rule the following definitions shall apply:
(d) STANDARDS
(i) Except as provided in Subsection (b)(1), a person shall not use in aerospace coating operations any coating
which contains VOC in excess of the following limits:
| VOC content, grams per liter of coating as Coating Category applied, less water and less exempt compounds | ||
| Adhesive Bonding Primers: | ||
| Structural | 850 | |
| For Elastomers and Elastomeric | 850 | |
| Adherends | 850 | |
| All Other Adhesive Bonding | ||
| Primers | 850 | |
| Adhesives: | ||
| Structural Autoclavable | 50 | |
| Structural Epoxy | 50 | |
| Structural Non-Autoclavable | 250 | |
| Elastomeric | 850 | |
| Fuel Tank Adhesives | 620 | |
| All Other Adhesives | 250 | |
| Antichafe Coatings | 600 | |
| Bearing Coatings | 620 | |
| Caulking and Smoothing Compounds | 850 | |
| Conformal Coatings | 750 | |
| Dry Lubricative Materials: | ||
| Fasteners Lubrication | 250 | |
| Non-Fasteners Lubrication | 880 | |
| Electromagnetic Radiation Effect Coatings | 800 | |
| Flight Test Coatings: | ||
| Use on Missiles, Targets | 420 | |
| All Others | 840 | |
| Form Release Agents | 800 | |
| Fuel Tank Coatings | 720 | |
| Heat Treatment Scale Inhibitors | 880 | |
| High Temperature Coatings | 850 | |
| High Temperature Resistant, Thermal Flash Resistant, Rain Erosion Resistant Coatings |
800 | |
| Impact Resistant Coatings | 420 | |
| High Temperature Coatings | 850 | |
| High Temperature Resistant, Thermal Flash Resistant, Rain Erosion Resistant Coatings |
800 | |
| Impact Resistant Coatings | 420 | |
| Line Sealer Maskants | 650 | |
| High Temperature Coatings | 850 | |
| High Temperature Resistant, Thermal Flash Resistant, Rain Erosion Resistant Coatings |
800 | |
| Impact Resistant Coatings | 420 | |
| Line Sealer Maskants | 650 | |
| Maskants for Bonding | 600 | |
| Maskants for Chemical Milling | ||
| Type I including Multi-Stage Maskants | 250 | |
| Type II | 160 | |
| All Other Chemical Milling | 250 | |
| Maskants for Chemical Processing Chemical Processing including Multi-Stage Maskants | 250 | |
| Optical Anti-Reflective Coatings | 700 | |
| Pretreatment Coatings | 780 | |
| Primers | 350 | |
| Primers Compatible with Rain Erosion Resistant Coatings | 850 | |
| Rain Erosion Resistant Coatings | 690 | |
| Sealants | 600 | |
| Hot Melt Sealants | 100 | |
| Solid Film Lubricants: | ||
| Fasteners Lubrication | 250 | |
| Non-Fasteners Lubrication | 880 | |
| Space Vehicle Coatings: | ||
| Electrostatic Discharge Protection | 800 | |
| Other Space Vehicle Coatings | 1000 | |
| Adhesives | 800 | |
| Temporary Protective Coatings | 250 | |
| Thermocontrol Coatings | 600 | |
| Topcoats | 420 | |
| Unicoats | 420 | |
| Wet Fastener Installation Coatings | 675 | |
| All Other Coatings | 420 | |
(ii) If each coating comprising a multi-stage maskant complies with the applicable VOC limit, then the multi-stage maskant is deemed compliant. Otherwise the compliance of a multi-stage maskant with the VOC limits in Subsection (d)(1)(i) shall be determined pursuant to Subsection (d)(1)(iii) in the following manner:
(A) For a multi-stage maskant for which all component coatings are applied by methods other than dip coating, the VOC content of the multi-stage coating shall be calculated either each day of operation using that calendar day as the averaging period or each calendar month using that calendar month as the averaging period; or
(B) For a multi-stage maskant for which some component coatings are applied by dip coating, the VOC content of the multi-stage coating shall be calculated each calendar month using that calendar month as the averaging period or that calendar month and the previous two consecutive calendar months as the averaging period.
(iii) The following formula shall be used to determine the VOC content per volume of coating less water and exempt compounds, as applied, of a multi-stage maskant over a given averaging period:

where:
VOCm = the VOC content per volume of coating less water and exempt compounds, as applied, of a multi-stage maskant.
VOCi = the VOC content per volume of coating less water and exempt compounds, as applied, of the iÕth component
coating of the multi-stage maskant.
Vi = the total coating volume of the iÕth coating component less water and exempt compounds, as applied,
used at an application station or added to a dip tank , as applicable, during the averaging period.
n = the total number of component coatings that comprise the multi-stage coating.
(iv) If a multi-stage maskant is determined to exceed the VOC limits of Subsection (d)(1)(i), then the owner or operator shall be deemed in violation of this rule for each day of the averaging period used to determine compliance pursuant to Subsection (d)(1)(iii) except for each day the owner or operator can demonstrate that no such noncompliant coatings were used.
The requirements of Subsection (d)(1) may be met using an Alternative Emission Control Plan (AECP) that has been approved pursuant to Rule 67.1.
Except as provided in Subsections (b)(1), (b)(2), and (b)(5), a person shall not apply aerospace coatings in aerospace coating operations subject to this rule except by means of the following application methods:
(i) Electrostatic spray application, or
(ii) Flow coat application, or
(iii) Dip coat application, or
(iv) Hand application methods, or
(v) Airless spray application for use with maskants and temporary protective coatings only, or
(vi) High-volume low-pressure (HVLP) spray application, or
(vii) Other coating application methods that are demonstrated to have transfer efficiency at least equal to one of the above application methods, and which are used in such a manner that parameters under which they were tested are permanent features of the method. Such coating application methods shall be approved in writing by the Air Pollution Control Officer prior to use.
Except as provided in Subsection (b)(1), a person shall not use a stripper in aerospace coating operations unless the stripper:
(i) Contains 400 grams of VOC per liter of material or less as applied, or
(ii) Has a total vapor pressure of VOC of 9.5 mm Hg or less at 68¡F (20¡ C).
Except as provided in Subsections (b)(1) and (b)(8), a person shall not use a material for surface cleaning or surface preparation of an aerospace component unless:
(i) The material contains 200 grams of VOC per liter of material or less as applied, or
(ii) The material has a total vapor pressure of VOC of 45 mm Hg or less at 68¡F (20¡ C), or
(iii) The material has an initial boiling point of 190û C (374û F) or greater at 760 mm Hg total pressure; or
(iv) The aerospace component is cleaned in an enclosed cleaning materialcontainer which is only opened when accessing parts or adding surface cleaning materials.
Except as provided in Subsection (b)(1), a person shall not clean aerospace coating application equipment unless the cleaning material:
(i) Contains 200 grams or less of VOC per liter of material; or
(ii) Has a total vapor pressure of VOC of 20 mm Hg or less at 68¡F (20¡ C); or
(iii) Has an initial boiling point of 190û C (374û F) or greater at 760 mm Hg total pressure; or
(iv) The cleaning material is flushed or rinsed through the application equipment in a contained manner that will minimize evaporation into the atmosphere; or
(v) The application equipment or equipment parts are cleaned in a container which is open only when being accessed for adding, cleaning, or removing application equipment or when cleaning material is being added, provided the cleaned equipment or equipment parts are drained to the container until dripping ceases; or
(vi) A system is used that totally encloses the component parts being cleaned during washing, rinsing and draining; or
(vii) Other application equipment cleaning methods are used that are demonstrated to be as effective as any of the equipment described above in minimizing the emissions of VOC to the atmosphere, provided that the method has been tested and approved by the Air Pollution Control Officer prior to use.
Except as provided in Subsections (b)(1), (b)(6), and (b)(7), a person shall not use a dip tank to apply Type I chemical milling maskants or maskants for chemical processing or component coatings of a multi-stage maskants to aerospace parts unless:
(i) The dip tank is covered except when being accessed to add or remove materials; take samples; visually inspect
the maskant level; clean, maintain or repair the tank; or apply maskant; and
(ii) The dip tank has a readily visible, permanent mark or line indicating the maximum allowable maskant level;
and
(iii) The dip tank has a freeboard ratio greater than or equal to 0.5; and
(iv) Maskant agitation is achieved by means other than gas agitation; and
(v) Material is added to the dip tank by means of submerged filling; and
(vi) Any dip tank lip exhaust ventilation system with an inlet located below the cover of the maskant application
dip tank is turned off and the ventilation duct closed when the maskant application dip tank is covered.
A person shall not use spray application equipment or any other means to dispose of waste coatings, coating components, surface preparation materials, or cleaning materials into the air, except when momentarily purging coating material from a spray applicator cap immediately before or after applying the coating material.
A person shall not specify the application of a coating subject to this rule for any aerospace coating operation in San Diego County if such application results in a violation of any provision of this rule. This prohibition is applicable to any written or oral contract under the terms of which any coating is applied to any aerospace component within San Diego County.
Except as provided in Subsections (b)(1), (b)(3), and (b)(4), a person using aerospace coatings subject to this rule shall provide to the Air Pollution Control Officer a list of all coatings applied in each affected facility. Such list shall contain all information required by Subsection (f)(1). The list shall also identify, for each aerospace coating, all applicable coating category uses, including allowable VOC content, specified in Subsection (d)(1)(i). The list shall be revised before any aerospace coating is used for purposes other than those previously identified on the list. The revised list shall be retained on site and provided to the Air Pollution Control Officer upon request. Information necessary to demonstrate that the intended use of a coating is consistent with the applicable definition of the coating use contained in Section (c) shall be provided to the District upon request.
A person shall not use any aerospace coating unless the coating is included on such list and is used only as the coating category specified on the list for that specific coating. If the intended use of a coating has been determined in writing by the Air Pollution Control Officer to be inconsistent with the applicable definition of the coating use contained in Section (c) or if the VOC content of a coating does not comply with the applicable limits specified in Subsection (d)(1), the coating shall be deleted from the list and shall not be used. Such determinations by the Air Pollution Control Officer shall not relieve the person using any aerospace coating from complying with the applicable definitions and VOC content limits of this rule.
(e) CONTROL EQUIPMENT
(i) Has been installed in accordance with an Authority to Construct; and
(ii) Includes an emission collection system which captures organic gaseous emissions, including emissions associated with applicable coating, equipment cleaning, and surface preparation operations, and transports the captured emissions to an air pollution control device; and
(iii) Has a combined emissions capture and control device efficiency of at least 85 percent by weight.
(i) Identify all key system operating parameters. Key system operating parameters are those necessary to ensure compliance with Subsection (e)(1)(iii), such as temperature, pressure, and/or flow rate; and
(ii) Include proposed inspection schedules, anticipated ongoing maintenance, and proposed recordkeeping practices regarding the key system operating parameters.
(f) RECORDKEEPING
Except as provided in Subsections (b)(1), (b)(3), and (b)(4), any person using coatings, strippers, thinners, surface cleaning materials or equipment cleaning materials in aerospace coating operations shall maintain records in accordance with the following requirements:
(i) Type and/or applicable category specified in Subsections (d)(1), (d)(3), (d)(4), and d(5) of each coating, stripper, thinner, surface cleaning and equipment cleaning material used, including manufacturer identification; and
(ii) Mix ratio of components; and
(iii) VOC content per volume of coating less water and exempt compounds, as applied; and
(iv) VOC content per volume of material, total vapor pressure of VOC, or initial boiling point of each stripper,
surface cleaning material, and equipment cleaning material, as applied.; and
(v) For each multi-stage maskant, the applicable maskant category specified in Subsection (d)(1), and the manufacturer identification of the component coatings that comprise the multi-stage maskant.
(i) For any materials not applied by dip coating, the amount of each coating, stripper, and thinner used; and
(ii) Inventory (dispensing) records for solvents used for equipment cleaning and surface cleaning operations; and
(iii) Material additions to coating application dip tanks.
(i) Maintain records in accordance with Subsections (f)(1) and (f)(2);
(ii) Maintain daily usage records for all coatings, strippers, cleaning and/or surface preparation materials not in compliance with Subsections (d)(1), (d)(3), (d)(4) or (d)(5) of this rule; and
(iii) Maintain daily records of key system operating parameters as approved in the Operation and Maintenance plan. Such records must be sufficient to document continuous compliance with Subsection (e)(1)(iii) during periods of emission producing activities.
All records shall be retained on site for at least three years and shall be made available to the District upon request.
(g) TEST METHODS