SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT



RULE 4603 SURFACE COATING OF METAL PARTS AND PRODUCTS
(Adopted April 11, 1991; Amended September 19, 1991; Amended May 21, 1992; Amended December 17, 1992; Amended May 20, 1993, Amended September 21, 2000)


1.0 Purpose
The purpose of this rule is to limit VOC emissions from the coating of metal parts and products. This rule also specifies the administrative and recordkeeping requirements and the test methods for determining the VOC content, the VOC emissions, the VOC capture efficiency, the acid content, the metallic or iridescent quality, and the VOC emissions from spray gun cleaning systems.

2.0 Applicability
The provisions of this rule shall apply to the surface coating of metal parts or products.

3.0 Definitions

    3.1 Aerospace Vehicles: the completed unit of any aircraft, helicopter, missile or space vehicle.

    3.2 Air Dried: a process whereby the coated object is cured or dried at ambient temperature or at a temperature up to a maximum of 194°F.

    3.3 Baked: a process whereby the coated object is heated above ambient temperature to a temperature above 194°F for the purpose of curing or drying.

    3.4 Brush Coating: the manual application of coatings using brushes or rollers.

    3.5 Camouflage Coating: a coating applied on military equipment to conceal such equipment from detection.

    3.6 Coils: metal sheets or strips which are rolled into coils for further industrial or commercial use.

    3.7 Continuous Coating: an enclosed coating system where spray nozzles coat metal parts and products as they are conveyed through the enclosure. Water wash zones control the inlet and outlet of the enclosure. Excess coating drains into a recirculation system.

    3.8 Dip Coating: the process in which a substrate is immersed in a solution (or dispersion) containing the coating material, and then withdrawn.

    3.9 Electrodeposition: a dip coating application method where the paint solids are given an electrical charge which is then attracted to a substrate.

    3.10 Electrostatic Application: a method of spray application of coatings where an electrostatic potential is created between the parts to be coated and the paint particles.

    3.11 Exempt Organic Compounds: all organic compounds not classified as volatile organic compounds (VOCs), as listed in Rule 1020 (Definitions).

    3.12 Extreme Performance Coating: a coating used on a metal surface where the coated surface is, in its intended use, exposed to any of the following:
      3.12.1 Industrial grade detergents, cleaners, or abrasive scouring agents.

      3.12.2 Unprotected shipboard conditions.

      3.12.3 Temperatures consistently in excess of 203°F or continuous exposure to corrosive environmental conditions.
    3.13 Flow Coating: a coating application system where paint flows over the part and the excess coating drains back into the collection system.

    3.14 Grams of VOC per Liter of Coating Applied, Excluding Water and Exempt Compounds: the weight of VOC per combined volume of VOC and coating solids and can be calculated by the following equation:

    3.15 Grams of VOC per liter of Material: the weight of VOC per volume of material and can be calculated by the following equation:



    3.16 High Performance Architectural Coating: a coating used to protect architectural subsections and which meets the requirements of the Architectural Aluminum Manufacturers Association publication number AAMA 605.2-1980.

    3.17 Heat Resistant Coating: any coating which during normal use must withstand temperatures of at least 400°F.

    3.18 High Gloss Coating: any coating which achieves at least 85% reflectance on a 600 meter when tested by ASTM Method D-523-89.

    3.19 High Temperature: any coating applied to a substrate which during normal use must withstand temperatures of at least 1000°F.

    3.20 High-Volume, Low-Pressure Spray: spray equipment used to apply a coating by means of a gun which operates between 0.1 and 10.0 psig air pressure.

    3.21 Light-Duty Truck: any truck having a manufacturer's maximum gross vehicle weight rating of under 6,001 pounds.

    3.22 Magnet Wire: wire used in electromagnetic field application in electrical machinery and equipment such as transformers, motors, generators, and magnetic tape recorders.

    3.23 Marine Vessel: any tugboat, tanker, freighter, passenger ship, barge, or other boat, ship, or watercraft. This includes both salt water and fresh water vessels.

    3.24 Metal Containers or Closures: the interior or the exterior of formed metal cans, drums, pails, or crowns; or flat metal sheets which are intended to be formed into cans, drums, pails, lids, or crowns.

    3.25 Metallic/iridescent Topcoat: any coating which contains more than 0.042 lb/gal of metal or iridescent particles, as applied, where such particles are visible in the dried film.

    3.26 Metal Parts and Products: any component or complete unit fabricated from metal, except those subject to the coating provisions of other source specific rules.

    3.27 Motor Vehicle: a vehicle which is self-propelled and is a device by which any person or property may be propelled, moved or drawn upon a highway, excepting a device moved by human power or used exclusively upon stationary rails or tracks.

    3.28 Polyester Resin Materials: materials including, but not limited to, unsaturated polyester resins such as isophthalic, orthophthalic, halogenated, biphenol-A, vinyl-ester, or furan resins, cross-linking agents, catalysts, gel coats, inhibitors, accelerators, promoters, and any other VOC containing materials in polyester resin coating operations.

    3.29 Polyester Resin Operations: methods used for the production or rework of products by mixing, pouring, hand-layup, impregnating, injecting, forming, winding, spraying, and/or curing unsaturated polyester resin materials with fiberglass, fillers, or any other reinforcement materials and associated cleanup.

    3.30 Pretreatment Wash Primer: any coating which contains no more than 12 percent solids by weight, and a minimum of one-half (0.5) percent acid by weight, is necessary to provide surface etching, and is applied directly to bare metal surfaces to provide corrosion resistance and adhesion.

    3.31 Repair: recoating portions of previously coated product to cover mechanical damage to the coating following normal painting operations.

    3.32 Roll Coating: the application of coatings from a paint through to a flat surface by a mechanical series of rollers.

    3.33 Silicone Release: a coating which contains silicone resin and has as its primary function the release of food products from metal surfaces such as baking pans.

    3.34 Solar Absorbent Coating: a coating which has as its primary purpose the absorption of solar radiation.

    3.35 Solid Film Lubricant: a very thin coating consisting of a binder system containing as its chief pigment material one (1) or more of the following: molybdenum disulfide, graphite, polytetrafluoroethylene (PTFE) or other solids that act as a dry lubricant between closely-fitting surfaces.

    3.36 Touch Up: that portion of the coating operation which is incidental to the main coating process but necessary to cover minor imperfections or to achieve coverage as required.

    3.37 Volatile Organic Compounds (VOCs): as defined in Rule 1020 (Definitions).

4.0 Exemptions

    4.1 The requirements of this rule, except for Section 6.2, shall not apply to coatings which emit or may emit VOCs in excess of the specified limits provided that the total facility emissions from the use of such coatings do not exceed 15 pounds in any one (1) day. Once a facility exceeds this exemption threshold it shall become subject to the requirements of this rule.

    4.2 The requirements of this rule shall not apply to touch-up and repair.

    4.3 Any source which is in full compliance with the provisions of this rule shall be exempt from otherwise applicable portions of Rule 4661 (Organic Solvents).

    4.4 The requirements of this rule shall not apply to the application of coatings to automobiles, light-duty trucks, aircraft, aerospace vehicles, marine vessels, can, coils, and magnetic wire.

    4.5 The provisions of this rule shall not apply to an operation subject to the requirements of Rule 4602 (Motor Vehicle and Mobile Equipment Coating Operations).

    4.6 For existing facilities, if an incineration device is added or modified for the sole purpose of complying with the requirements of this rule, such a device shall be exempt from the Best Available Control Technology and the Offset requirements of Rule 2201 (New and Modified Stationary Source Review Rule).

    4.7 The provisions of this rule shall not apply to polyester resin operations and the application of polyester resin materials to metal parts and products.

5.0 Requirements

    5.1 General Limits: Except as otherwise provided by this rule, no person shall apply to any metal part or product 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 applied, (less water and exempt compounds):
      5.1.1 Baked Coating 275 g/l (2.3 lb/gal)

      5.1.2 Air-Dried Coating 340 g/l (2.8 lb/gal)

      5.1.3 Dip coating of steel joists (SIC 3441), Air-dried, effective September 21, 2000.
        5.1.3.1 340 g/l (2.8 lb/gal) for coatings with a viscosity, as applied, of more than 45.6 centistokes at 78°F or an average dry-film thickness of greater than 2.0 mils;

        5.1.3.2 400 g/l (3.32 lb/gal) for coatings with a viscosity, as applied, of less than or equal to 45.6 centistokes at 78°F and an average dry-film thickness of less than or equal to 2.0 mils.
    5.2 Specialty Coating Limitations: A person shall not apply to any metal part or product any specialty coating with a VOC content in excess of the limits, expressed as grams of VOC per liter (or pounds per gallon) of coating applied, (less water and exempt compounds):


    5.3 Control Requirements: The requirements of Sections 5.1 and 5.2 shall not apply to any person who installs and operates air pollution control equipment with a minimum overall capture and control efficiency of 90 percent or more on a mass basis as determined in Section 6.3. The control equipment shall be under District permit. The overall efficiency shall be equivalent or greater than those emission reduction levels achieved by any requirement specified in Sections 5.1 or 5.2.

    5.4 Evaporative Loss Minimization: Effective November 1, 1991, a person shall:
      5.4.1 Only use solvents with a VOC content of less than 200 grams VOC per liter of material (1.67 lb/gal) for cleanup surface preparation, excluding cleaning of coating application equipment;

      5.4.2 Use closed containers for the storage or disposal of solvent-laden cloth or paper used for surface preparation and cleanup. Containers shall be nonabsorbent;

      5.4.3 Store fresh or spent solvent, coating, adhesive, catalyst, or thinner in closed containers; and

      5.4.4 Not use VOC-containing materials for spray equipment cleanup unless an enclosed system or equipment proven to be equally effective is used for cleaning. An enclosed system must totally enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining procedures.

    5.5 Application Equipment Requirements: A person shall not use or operate any coating application equipment on any metal parts and products subject to the provisions of this rule unless one of the following methods is used:
      5.5.1 Electrostatic application;
      5.5.2 Electrodeposition;
      5.5.3 High-volume, low-pressure spray;
      5.5.4 Flow coating;
      5.5.5 Roll coating;
      5.5.6 Dip coating;
      5.5.7 Brush coating; or
      5.5.8 Continuous coating.

    5.6 Prohibition of Specification: No person shall solicit or require for use or specify the application of a coating subject to this rule if such use or application results in a violation of any 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 is to be applied to any metal part or product at any physical location within the District.

6.0 Administrative Requirements

    6.1 Labeling Requirements
      6.1.1 VOC Content: Each container or accompanying data sheet of any coating subject to this rule and manufactured after April 11, 1992, shall display the maximum VOC content of the coating, as applied, and after any thinning as recommended by the manufacturer. VOC content shall be displayed as grams of VOC per liter of coating (less water and exempt compounds). VOC content displayed may be calculated using product formulation data, or may be determined using the test method in Section 6.3. For determination of compliance and enforcement of the limits specified in Section 5.0 of this rule, the VOC content of any coating determined to exceed its applicable limit through the use of either product formulation data or the test method in Section 6.3.1 shall constitute a violation of this rule.

      6.1.2 Thinning Recommendations: Each container or accompanying data sheet of any coating subject to this rule and manufactured after April 11, 1992, shall display a statement of the manufacturer's recommendation regarding thinning of the coating. This requirement shall not apply to the thinning of coatings with water.

    6.2 Recordkeeping
      6.2.1 Any person subject to Section 5.0 or exempt by Section 4.1 shall comply with the following requirements:

      6.2.2 Maintain a current list of coatings and solvents in use which contains all of the coating data necessary to evaluate compliance, including the following information, as applicable:
        6.2.2.1 mix ratio of components used;

        6.2.2.2 VOC content and specific chemical constituents of coatings as applied, and

        6.2.2.3 VOC content and specific chemical constituents of solvents used for surface preparation and cleanup.
      6.2.3 Maintain records which include the following information:
        6.2.3.1 volume coating/solvent mix ratio,

        6.2.3.2 VOC content(lb/gal) and, for dip coating operations, viscosity (cSt) of coating,

        6.2.3.3 volume of each coating used (gallons), and

        6.2.3.4 quantity of cleanup solvent used (gallons).

        6.2.3.5 quantity of cleanup solvent used (gallons).

      6.2.4 Consistent records may be kept in grams/liter and liters instead of pounds/gallon and gallons. Facilities subject to the requirements of Section 5.0 shall maintain such records on a daily basis.

      6.2.5 Facilities which are exempt by Section 4.1 may maintain such records on an extended basis provided the records substantiate emissions are less than 15 pounds per day for the entire extended period.

      6.2.6 Such records shall be retained and made available for inspection by the APCO for the previous 24 month period.

    6.3 Test Methods

      6.3.1 Analysis of Samples: Samples of VOC as specified in this rule shall be analyzed by EPA Method 24 and analysis of halogenated exempt compounds shall be analyzed by ARB Method 432.

      6.3.2 Determination of Emissions: Emissions of VOC shall be measured by EPA Method 25, 25a, or 25b, as applicable, and analysis of halogenated exempt compounds shall be analyzed by ARB Method 422.

      6.3.3 Capture efficiency shall be determined using methods in 55 Federal Register (FR) 26865 (June 29, 1990) as described under (a)(4)(iii) - Capture System Efficiency Test Protocols and Appendix B - Volatile Organic Material Measurement Techniques for Capture Efficiency. The procedure described under (a)(4)(iii)(2) of the above referenced FR shall be modified as follows: If a stationary source owner or operator uses a control device designed to collect and recover VOC (e.g., a carbon adsorber), an explicit measurement of capture efficiency is not necessary if the conditions described in 55 FR 26865 are met. The overall emission reduction efficiency shall be determined each day by directly comparing the input liquid VOC to the recovered liquid VOC. The procedure for use in this situation is specified in 40 CFR 60.433 with additional modifications described in 55 FR 26865.

      6.3.4 The quantification of coating as a metallic/iridescent topcoat shall be determined by South Coast Air Quality Management District "Spectrographic Method for the Analysis of Carbon Dust and Carbon Laminates", December 1985.

      6.3.5 Acid Content: Measurement of acid content of pre-treatment wash primers shall be conducted and reported in accordance with South Coast Air Quality Management District "Laboratory Methods of Analysis for Enforcement Samples, ASTM D1613-85 Standard Test Method for Acidity in Volatile Solvents and Chemical Intermediates used in Paint, Varnish, Lacquer, and Related Products", December, 1986.

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


7.0 Compliance Schedule:

    7.1 Any person who becomes subject to the requirements of this rule through loss of exemption shall comply with the following increments of progress:
      7.1.1 Within six (6) months from date the exemption was lost, submit a complete application for an Authority to Construct, if necessary.

      7.1.2 Within 12 months from date the exemption was lost, be in full compliance with the requirements of this rule.
    7.2 The owner or operator of any surface coating of metal parts and products operation which is subject to the requirements of this rule and which is installed or constructed on or after April 11, 1991, shall be in full compliance with the requirements of this rule at the time of initial operation.