YOLO-SOLANO AIR QUALITY MANAGEMENT DISTRICT

RULE 2.25 - METAL PARTS AND PRODUCTS COATING OPERATIONS
(Revised August 13, 1997)

INDEX

100 GENERAL

101 PURPOSE

102 APPLICABILITY

110 EXEMPTION - LOW USAGE OF NON-COMPLIANT COATINGS

111 EXEMPTION - SPECIFIC COATINGS

112 EXEMPTION - SPECIFIC COATING OPERATIONS

113 EXEMPTION - PERFORMANCE TESTING

114 EXEMPTION - AUTOMOTIVE AND TRUCK REFINISHING


200 DEFINITIONS

201 ADHESIVE

202 AIR-DRIED COATING

203 BAKED COATING

204 CAMOUFLAGE COATING

205 COATING

206 ENCLOSED GUN WASHER

207 ETCHING FILLER

208 EXEMPT COMPOUNDS

209 EXTREME PERFORMANCE COATING

210 HAND COAT

211 HEAT-RESISTANT COATINGS

212 HIGH GLOSS COATING

213 HIGH PERFORMANCE ARCHITECTURAL COATING

214 HIGH TEMPERATURE COATING

215 HIGH-VOLUME, LOW-PRESSURE (HVLP) SYSTEM

216 METAL PARTS AND PRODUCTS

217 METALLIC TOP COATING

218 MOLD-SEAL COATING

219 PAN BACKING COATING

220 POWDER COATING

221 PRETREATMENT WASH PRIMER

222 REPAIR COATING

223 SAFETY-TEMPERATURE INDICATING COATING

224 SILICONE RELEASE COATING

225 SOLAR-ABSORBANT COATING

226 STENCIL COATING

227 TEXTURED FINISH

228 TOUCH-UP COATING

229 VACUUM-METALIZING COATING

230 VOLATILE ORGANIC COMPOUND (VOC)


300 STANDARDS

301 COATING LIMITS

302 APPLICATION METHODS

303 ADD-ON CONTROLS

304 SURFACE PREPARATION AND CLEAN-UP SOLVENTS

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF SPECIFICATIONS

402 QUALIFICATION FOR CLASSIFICATION AS EXTREME PERFORMANCE COATING

403 COMPLIANCE STATEMENTS

404 CALCULATION FOR DETERMINATION OF VOC CONTENT PER VOLUME OF COATING

405 CALCULATION FOR DETERMINATION OF VOC CONTENT PER VOLUME OF SURFACE PREPARATION OR CLEAN-UP MATERIAL


500 MONITORING AND RECORDS

501 TEST METHODS

502 RECORDS


100 GENERAL

101 PURPOSE: The purpose of this rule is to limit the emission of volatile organic compounds in metal parts and products coating operations.
102 APPLICABILITY: Except as otherwise provided in Sections 110, 111, 112, 113, and 114 the provisions of this rule are applicable to the surface coating of metal parts and products.
110 EXEMPTION - LOW USAGE OF NON-COMPLIANT COATINGS: The provisions of Section 301 shall not apply to coatings used in volumes of less than 50 gallons per year.
111

EXEMPTION - SPECIFIC COATINGS: The provisions of Section 300 shall not apply to the following:

111.1 Stencil coatings;

111.2 Safety-temperature indicating coatings;

111.3 Powder coatings; and

111.4 Adhesive coatings upon the effective compliance dates of Rule 2.31, ADHESIVES.

112 EXEMPTION - SPECIFIC COATING OPERATIONS: The provisions of Section 302 shall not apply to the application of touch-up coatings, repair coatings, textured finish coatings, metallic coatings which have a metallic content of more than 30 grams per liter, mold-seal coatings, and to facilities that use less than one (1) gallon of coating per day, as applied, including any VOC-containing materials added to the original coating as supplied by the manufacturer.
113 EXEMPTION - PERFORMANCE TESTING: The provisions of Sections 301 and 302 shall not apply to the application of coatings while conducting performance tests on the coatings at paint manufacturing facilities provided that written prior approval has been obtained from the Air Pollution Control Officer.
114 EXEMPTION - AUTOMOTIVE AND TRUCK REFINISHING: The provisions of this rule shall not apply to coating operations subject to the provisions of Rule 2.26, MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS, upon its effective compliance dates.

200 DEFINITIONS

201 ADHESIVE: Any substance that is used to bond surfaces together by attachment.
202 AIR-DRIED COATING: A coating that is cured at a temperature below 90oC (194oF).
203 BAKED COATING: A coating that is cured at a temperature at or above 90oC (194oF).
204 CAMOUFLAGE COATINGS: A coating used, principally by the military, to conceal equipment from detection.
205 COATING: A material which is applied to a surface and which forms a continuous film in order to beautify and/or protect such surface.
206 ENCLOSED GUN WASHER: A spray gun washing system that has an enclosed solvent container, and uses non-atomized solvent flow to flush the spray equipment and collects and returns the discharged solvent to the enclosed container.
207 ETCHING FILLER: A coating that contains at least 0.5 percent acid by weight, and is used instead of applying a pretreatment coating followed by a primer.
208 EXEMPT COMPOUNDS: For a current listing of exempt compounds see Section 214 of District Rule 1.1, General Provisions and Definitions.
209 EXTREME PERFORMANCE COATING: A coating used on a metal surface where the coated surface, in its intended use, is frequently or chronically exposed to:

209.1 Corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical mixtures or solution;

209.2 Repeated exposure to temperatures in excess of 250oF; or

209.3 Repeated heavy abrasion, including mechanical wear and repeated scrubbing with industrial grade solvents, cleansers, or scouring agents.
210 HAND COAT: The application of coatings by manually held nonmechanically operated equipment. Such equipment includes paint brushes, hand rollers, caulking guns, trowels, spatulas, syringe daubers, and sponges.
211 HEAT-RESISTANT COATING: A coating applied to a substrate that must withstand a temperature of at least 204oC (400oF) during normal use.
212 HIGH GLOSS COATING: A coating which, when tested in accordance with ASTM Test Method D-523-1989, has a reflectance of 85 percent or more on a 60o meter.
213 HIGH PERFORMANCE ARCHITECTURAL COATING: A coating used to protect architectural subsections and which is required to meet the specifications of the Architectural Aluminum Manufacturer Association's publication number AAMA 605.2-1980.
214 HIGH TEMPERATURE COATING: A coating applied to a substrate that must withstand a temperature of 538oC (1000oF) during normal use.
215 HIGH-VOLUME, LOW-PRESSURE (HVLP) SYSTEM: A coating application system which is operated on a delivered air pressure between 0.1 and 10 psig.
216 METAL PARTS AND PRODUCTS: Any components or complete units fabricated from metal, except those subject to the provisions of other District source specific rules.
217 METALLIC TOP COATING: A coating which contains more than 5 grams of metal per liter of coating, as applied, where such particles are visible in the dried film.
218 MOLD-SEAL COATING: The initial coating applied to a new mold or repaired mold and associated tooling to provide a smooth surface which, when coated with a mold release coating, prevents products from sticking to the mold or to the tooling.
219 PAN BACKING COATING: A coating applied to the surface of pots, or other cooking implements that are exposed directly to a flame or other heating elements.
220 POWDER COATING: Any coating applied as a dry (without solvent or other carrier) finely divided solid, which when melted and fused, adheres to the substrate as a paint film.
221 PRETREATMENT WASH PRIMER: A coating which contains no more than 12 percent solids by weight, at least 0.5 percent acid by weight, is used to provide surface etching, and is applied directly to metal surfaces to provide corrosion resistance, adhesion, and ease of stripping.
222 REPAIR COATING: A coating used to recoat portions of a product which has sustained mechanical damage to the coating following normal painting operations.
223 SAFETY-TEMPERATURE INDICATING COATING: A coating which changes physical characteristics, such as color, to indicate unsafe conditions.
224 SILICONE RELEASE COATING: Any coating which contains silicone resin and is intended to prevent food from sticking to metal surfaces such as baking pans.
225 SOLAR-ABSORBANT COATING: A coating which has as its prime purpose the absorption of solar radiation.
226 STENCIL COATING: A coating which is rolled or brushed onto a template or stamp in order to add identifying letters and/or numbers to metal parts and products.
227 TEXTURED FINISH: A rough surface produced by spraying large drops of coating onto a previously applied coating.
228 VACUUM-METALIZING COATING: The undercoat applied to the substrate on which the metal is deposited or the overcoat applied directly to the metal film.
229 VOLATILE ORGANIC COMPOUND: Any compound containing at least one atom of carbon, except exempt compounds listed in Section 214 of Rule 1.1, General Provisions and Definitions.

300 STANDARDS

301 COATING LIMITS: Except as indicated, effective April 27, 1994, a person shall not apply to metal parts and products any coatings, including any VOC-containing materials added to the original coating supplied by the manufacturer, which contain VOC in excess of the limits in Table 1.

TABLE 1

Grams of VOC per Liter (or Pounds of VOC per Gallon) of Coating Less Water, and Less Exempt Compounds

VOC CONTENT G/L(LBS/GAL)

COATING CATEGORY

BAKED

AIR DRIED

General Coatings

275 (2.3)

340 (2.8)

Specialty Coatings: Etching Filler

420 (3.5)

420 (3.5)

Solar-Absorbent

360 (3.0)

420 (3.5)

Heat-Resistant

360 (3.0)

420 (3.5)

High Gloss

360 (3.0)

420 (3.5)

Metallic

360 (3.0)

420 (3.5)

Extreme Performance

420 (3.5)

420 (3.5)

Silicone Release

420 (3.5)

420 (3.5)

High Performance Architectural

420 (3.5)

420 (3.5)

Camouflage

360 (3.0)

420 (3.5)

Vacuum-Metalizing

420 (3.5)

420 (3.5)

Mold-Seal

420 (3.5)

420 (3.5)

High Temperature

420 (3.5)

420 (3.5)

Pan Backing

420 (3.5)

420 (3.5)

Pretreatment Wash Primer*

420 (3.5)

420 (3.5)

* No maximum solids content restriction.
302

APPLICATION METHODS: Effective April 27, 1995 a person shall not apply coatings to metal parts and products subject to the provisions of this rule unless the coatings are applied using properly operated equipment, and by using one of the following application methods or other high transfer efficiency application equipment which has been approved, in writing, by the Air Pollution Control Officer:

302.1 Electrostatic attraction operated in accordance with manufacturer's recommendations;

302.2 High-Volume, Low-Pressure (HVLP) spray system operated in accordance with manufacturer's recommendations;

302.3 Flow coat;

302.4 Dip coat;

302.5 Hand coat; or

302.6 Roll coat.

303 ADD-ON CONTROLS: Alternatively, a person may comply with the provisions of Section 301 by using air pollution control equipment, provided that the overall efficiency (capture efficiency multiplied by destruction efficiency) of the system shall not be less than 85 percent by weight in reducing volatile organic compounds. The emission control system, as well as the operational and maintenance plan necessary to compliance on an on-going basis, shall be approved in writing by the Air Pollution Control Officer.
304

SURFACE PREPARATION AND CLEAN-UP SOLVENTS:

304.1 Effective April 27, 1995 a person shall not use materials which have a VOC content in excess of 200 grams per liter of material for surface preparation unless such material has an initial boiling point of greater than 19oC as determined by the method specified in Section 501.6.

304.2 A person shall not use VOC-containing materials for the clean-up of equipment used in coating operations unless:

  1. Such material is collected in a container which is closed when not in use; and
  2. The spray equipment is disassembled and cleaned in an enclosed gun washer or other low emission washing system that has been demonstrated to be at least equivalent to an enclosed system. The alternative low emission washing system must have approval in writing by the Air Pollution Control Officer.

304.3 A person shall use closed containers for the disposal of cloth, paper, or other materials including solvent and spent solvent used for surface preparation, clean-up, and paint removal.

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF SPECIFICATION: A person shall not specify the use of any coating to be applied to any metal parts and products subject to the provisions of this rule that does not meet the limits and requirements of this rule where such applications result in a violation of this rule. The requirements of this Section shall apply to all written or oral contracts.
402 QUALIFICATION FOR CLASSIFICATION AS EXTREME PERFORMANCE COATING: A person shall apply to the Air Pollution Control Officer to have a coating classified as an extreme performance coating prior to application of such coating. The Air Pollution Control Officer may classify a coating as an extreme performance coating provided that the petitioner demonstrates that the intended use of each coated object would require an extreme performance coating and has successfully demonstrated that general compliant coatings are unsuitable.
403 COMPLIANCE STATEMENT REQUIREMENT: Effective April 27, 1994, manufacturers of coatings subject to this rule shall provide on coating containers or on separate data sheets the designation of VOC content (as supplied) including any recommended thinning ratio. The VOC content shall be expressed as grams per liter of coating less water and less exempt compounds.
404

CALCULATION FOR DETERMINATION OF VOC CONTENT PER VOLUME OF COATING: The VOC content per volume of coating shall be calculated less water and less exempt compounds as follows:

VOC = Ws - Ww - Wes
    Vm - Vw - Ves
where:

W s = Weight of volatile compounds in grams

Ww = Weight of water in grams

Wes = Weight of exempt compounds in grams

Vm = Volume of coating materials in liters

Vw = Volume of water in liters

Ves = Volume of exempt compounds in liters

405

CALCULATION FOR DETERMINATION OF VOC CONTENT PER VOLUME OF SURFACE PREPARATION OR CLEANUP MATERIAL: The VOC content per volume of surface preparation and cleanup materials is calculated using the following equation:

VOC

=

Ws - Ww - Wes

   

Vm

where:

w = 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

500 MONITORING AND RECORDS

501

RECORDS:

501.1 Coating and Solvent Records: Any person subject to the requirements of Section 300 of this Rule shall maintain:

  1. A current list of coatings and solvents in use, which includes the following information:
    1. Name and manufacturer information;
    2. Mixing instructions;
    3. VOC content of coatings and surface preparation and cleanup solvents as applied;
    4. Weight percent water;
    5. Weight percent exempt solvent; and
    6. Thinning solvent composition and density
  2. The amounts of coatings and VOCs used according to the following schedule:
    1. Monthly records showing the types and amounts of coatings used that meet the coating standard contained in Section 301; and
    2. Daily records showing the types and amounts of coatings used that do not meet the requirements of Section 301, and whether such usage was in conjunction with emission control equipment.
  3. Usage records of coatings that are exempt from the requirements of this rule by Section 110 can be kept on a quarterly basis.
  4. Usage records of coatings shall be kept on a daily basis by those facilities, using less than one gallon per day, exempted under Section 112.
  5. Monthly records showing the types and amounts of solvents used for surface preparation and cleanup.

501.2 Emission Control Equipment Records: Any person complying with the provisions of Section 301 by using air pollution control equipment shall maintain daily records of key system operating parameters, such as temperatures, pressures, and/or flowrates, for the emission control equipment which will demonstrate continuous operation and compliance of the equipment during periods of emission producing activity.

501.3 Record Retention: All records maintained pursuant to this Section shall be retained for the previous two calendar years, and shall be made available to the Air Pollution Control Officer upon request.

502

TESTING PROCEDURES:

502.1VOC Content: The Volatile organic compound content of coatings and solvents subject to the provisions of this rule excluding exempt compounds shall be determined by procedures contained in EPA Reference Test Method 24 (40 CFR 60, Appendix A).

502.2 Exempt Compounds: Measurement of exempt compounds shall be conducted and reported in accordance with ASTM Test Method D 4457-85. For exempt compounds where no reference test method is available, a facility requesting the exemption shall provide appropriated test methods approved by the Air Pollution Control Officer and approvable by EPA.

502.3 Acid Content: Measurement of acid content shall be conducted and reported in accordance with ASTM Test Method D 1613-85.

502.4 Metal Content: Measurement of metal content shall be conducted and reported in accordance with the South Coast Air Quality Management District's Spectrographic Method 311.

502.5 Capture Efficiency: The measurement of capture efficiency of an emission control system shall be determined by and reported in accordance with 40 CFR 52.741, Appendix B, "VOM Measurement Techniques for Capture Efficiency".

502.6 Boiling Range of Liquid Containing VOC: Determinations of the initial boiling point of a liquid containing VOC shall be performed in accordance with ASTM Test Method D 1078-86.

502.7 Control Efficiency: Determination of control efficiency shall be conducted and reported in accordance with EPA Method 25A.

502.8 Solids Content: Measurement of solids content shall be conducted and reported in accordance with EPA Reference Test Method 24.

502.9 Transfer Efficiency: The transfer efficiency for alternative coating applications methods described in Section 302 of this Rule shall be determined in accordance with the South Coast Air Quality Management District "Procedure for Testing Spray Equipment Transfer Efficiency (TE)".

502.10 Spray Gun Cleaning Systems: The determination of emissions of VOC from spray gun cleaning systems shall be made using South Coast Air Quality Management District "General Test Method for Determining Solvent Losses from Spray Gun Cleaning Systems"' dated October 3, 1989.