VENAPCD RULE 74.12 SURFACE COATING OF METAL PARTS AND PROD.

LAST REVISED 11/17/92

Rule 74.12. Surface Coating of Metal Parts and Products

(Adopted 11/19/85, Revised 8/26/86, 5/16/89, 11/17/92)

A. Applicability

This rule is applicable to any person who applies or

specifies the use of surface coatings to metal parts or

products.

Any person who applies or specifies the application of

surface coatings to either stationary structures or their

appurtenances is subject to Rule 74.2 instead of this rule.

Any person who applies or specifies the application of

surface coatings to aerospace vehicles or components is

subject to Rule 74.13 instead of this rule.

B. Requirements

1. Coating Reactive Organic Compounds (ROC) Content

Limits: No person shall apply or specify the use of any

coating with a reactive organic compounds (ROC)

content, less water and less exempt organic compounds,

in excess of the following limits, as applied:

Limits

Grams of ROC Per Liter

of Coating, Less Water

and Less Exempt Organic Compounds



AIR

COATING DRIED lb/gal BAKED lb/gal DATE

All coatings except 340 2.8 275 2.3

For the following:

Camouflage 420 3.5 360 3.0 7/01/93

Extreme Performance 420 3.5 360 3.0

Etching Filler 420 3.5 420 3.5 7/01/93

Heat Resistant 420 3.5 360 3.5 7/01/93

High Gloss 420 3.5 360 3.0 7/01/93

High Performance

Architectural 750 6.3 750 6.3 7/01/93

High Temperature 550 4.6 550 4.6 7/01/93

Laboratory Furniture 340 2.8 340 2.8

Metallic 420 3.5 360 3.0

Mold Seal 750 6.3 750 6.3 7/01/93

Pan Backing 480 4.0 480 4.0 7/01/93

Pretreatment Wash

Primer 340 2.8 275 2.3

Silicone Release 420 3.5 420 3.5 7/01/93

Solar Absorbent 420 3.5 360 3.0 7/01/93

Vacuum Metalizing 800 6.7 800 6.7 7/01/93

2. Add-on Control Equipment Option: In lieu of

complying with the coating ROC content limits specified

in Subsection B.1, air pollution control equipment may

be used provided:

a. The combined capture and control efficiency

reduces emissions by at least 85 percent by

weight, and

b. The Air Pollution Control Officer (APCO) issues

written approval for such equipment in the form of

an Authority to Construct and Permit to Operate,

and

c. Combustion temperature is continuously

monitored, when operating a thermal incinerator,

and

d. Exhaust gas and inlet gas temperature is

continuously monitored, when operating a catalytic

incinerator, and

e. Control device efficiency is continuously

monitored, when operating a carbon adsorber or

control system other than a thermal or catalytic

incinerator, and

f. Monitoring equipment is used in accordance with

vendor or manufacturer specifications.

3. Transfer Efficiency: No person shall apply coatings

subject to this rule except by using properly operated

equipment and by using one or more of the following:

a. Electrostatic application operated at a minimum

of 60 kV power

b. Flow coat application

c. Dip coat application

d. High volume, low pressure application

(HVLP)

e. Hand application methods

f. Any other application method that is

demonstrated to achieve at least 65 percent

transfer efficiency.

4. Surface Preparation and Equipment Cleanup:

a. No person shall use any material which contains

ROC in excess of 200 grams per liter of material

for substrate surface cleaning. Effective July 1,

1993 no person shall use any material which

contains ROC in excess of 70 grams per liter of

material for substrate surface cleaning.

b. Closed containers shall be used for the storage

or disposal of solvent-containing cloth or paper

used for surface preparation and cleanup.

Containers shall be nonabsorbent.

c. No person shall use organic compounds for spray

equipment cleanup unless:

1) An enclosed gun washer or "low emission

spray gun cleaner" that has been approved in

writing by the APCO is properly used for

equipment cleaning, and

2) The composite vapor pressure of organic

compounds used is less than 45 mm Hg at a

temperature of 20 oC. Until July 1, 1993,

this requirement does not apply to any "low

emission spray gun cleaner".

5. All ROC containing materials including but not

limited to surface coatings, cleanup solvents, or

surface preparation materials shall be stored in closed

containers which are nonabsorbent and do not leak.

6. Coating Compliance Statement: Effective July 1, 1993

the manufacturer of coatings subject to this rule shall

designate on product labels or data sheets, the ROC

content or the Volatile Organic Compounds (VOC) content

of coatings including coating reducers and catalysts,

as supplied. This designation shall include

recommendations regarding thinning, reducing, or mixing

with any other ROC containing materials, and express

the coating ROC or VOC content on an as applied basis

when used in accordance with the manufacturer's

recommendations. All letters and numbers used to

designate ROC or VOC content on product labels shall be

visible and legible.

7. Liquid Cleaning Material Compliance Statement:

Effective July 1, 1993 the manufacturer of liquid

cleaning materials used in coating operations shall

designate on product labels or data sheets the ROC

content of cleaning materials as supplied. This

designation shall include recommendations regarding

mixing with any other ROC containing materials, and

express the cleaning material ROC content when used in

accordance with the manufacturer's recommendations.

All letters and numbers used to designate ROC or VOC

content on product labels shall be visible and legible.

8. Prohibition of Specifications: No person shall

specify, solicit or require the application of any

coating to any metal part or product, or the use of any

equipment cleaning solvent, if such application or use

would violate this rule. This prohibition applies to

all written and oral contracts for which any coating

subject to this rule is to be applied to any metal part

or product at any location in Ventura County.

9. A person currently permitted to apply any of the

coating types in Subsection B.1 with a compliance date

of July 1, 1993, but with an ROC content less than

required above, shall obtain a Permit to Operate from

the APCO to use any such coating types having an ROC

content equal to the above limit.

C. Exemptions

1. Subsection B.1 of this rule does not apply to any one

coating provided:

a. Usage of such coating at a stationary source has

not exceeded 20 gallons in any calendar year, and

b. No complying coatings are available, and

c. Total usage of all noncomplying coatings has not

exceeded 55 gallons in any calendar year.

Any person claiming this exemption shall demonstrate

the lack of available coatings to the APCO on an annual

basis and shall keep records in accordance with

Subsection D.5.

2. This rule does not apply to:

a. Aircraft or aerospace vehicle coating operations

b. Marine vessel exteriors

c. Motor vehicle and mobile equipment coating.

3. Section B of this rule does not apply to stationary

sources emitting not more than 3 pounds of ROC per day

and not more than 200 pounds of ROC per year from

coatings, thinners, and any ROC containing materials

used in metal parts or products coating operations.

Any person claiming this exemption shall maintain

adequate records in accordance with Subsection D.4 to

substantiate their exempt status.

4. Any coating or cleanup solvent subject to this rule

is exempt from Rule 66.

D. Recordkeeping Requirements

1. Any person subject to this rule shall:

a. Maintain and make available to the APCO, a

current list of all coatings that provides all

information necessary to evaluate compliance,

including the following, as applicable:

1) The name and manufacturer of each coating

and any catalysts and reducers used with each

coating

2) Mix ratio of components used in coatings

3) ROC content of coatings, as applied

4) Coating category from Subsection B.1 of

each coating used.

2. Any person subject to this rule shall maintain

records of the monthly volume of each complying coating

and daily volume of each noncompliant coating applied.

3. Any person subject to the requirements of this rule

shall maintain records which show the following for

each ROC containing material used for equipment

cleaning and each ROC containing material used for

substrate surface cleaning:

a. Type

b. ROC content in grams per liter of material

c. Composite vapor pressure of organic compounds

(equipment cleaning materials only).

4. Any person claiming exemption from Section B of this

rule pursuant to Subsection C.3 shall:

a. Maintain and make available to the APCO, a

current list of all coatings, catalysts, reducers,

and liquid cleaning materials. This list shall

provide all of the information necessary to

evaluate exemption applicability, including:

1) The name and manufacturer of all coatings,

catalysts, reducers, and ROC containing

liquid cleaning materials used; and

2) Mix ratio of coating components used; and

3) ROC content of each coating and each liquid

cleaning material as applied or used; and

4) Coating category from Subsection B.1

5) Daily volume of each coating, substrate

surface cleaner, and equipment cleaning

material used.

5. Any person claiming the coating exemption in

Subsection C.1 shall maintain records of each

noncomplying coating which show the following:

a. Coating category from Subsection B.1.

b. Data sheets that identify the name and

manufacturer of all noncomplying coatings used or

unused

c. Monthly volume applied

d. ROC content as applied.

6. Any person complying with this rule by means

of Subsection B.2 shall keep the following records:

a. A log of operating time for the capture system,

control device(s), monitoring equipment, and

associated coating line(s).

b. A log for the capture system, control device(s),

and monitoring equipment detailing all routine and

non-routine maintenance performed including dates

and durations of any equipment outages.

7. Any person who operates an emissions monitor shall

keep daily records of the applicable continuous

monitoring information required by Subsections B.2.c,

B.2.d, and B.2.e.

8. All lists and records required by this section shall

be maintained for a minimum of two (2) years and be

available for inspection by the APCO.

E. Test Methods

1. The reactive organic compounds content of coatings

and liquid cleaning materials, shall be determined

using EPA Reference Method 24 (40 CFR 60, Appendix A).

2. Transfer efficiency shall be determined in accordance

with the South Coast Air Quality Management District

method entitled "Spray Equipment Transfer Efficiency

Test Procedure for Equipment Users".

3. The composite vapor pressure of organic compounds in

liquid cleaning materials shall be determined by

quantifying the amount of each organic compound in the

blend using gas chromatographic analysis (ASTM E260-91)

or by using product formulation data, and by summing

the partial pressures of each compound at 20o C. For

the purpose of this calculation, Raoult's Law applies

to the blend. The vapor pressure of each single

component compound may be determined from ASTM Method

D2879-86 or may be obtained from a published source

approved by the APCO, such as the sources referenced in

40 CFR 52.741.

4. The capture and control efficiency in Subsection B.2

shall be determined using methods in 40 CFR 52.741

(a)(4)(iii) - Capture System Efficiency Test Protocols,

(a)(4)(iv) Control Device Efficiency Testing and

Monitoring and Appendix B of Section 52.741 - Volatile

Organic Material Measurement Techniques for Capture

Efficiency.

5. The acid content of pretreatment wash primers and

etching fillers shall be determined by ASTM D1613-85.

6. The solids content of etching fillers shall be

determined using EPA Reference Method 24.

7. The metal content of metallic coatings shall be

determined by Spectrographic Method 311 in the South

Coast Air Quality Management District manual,

"Laboratory Methods of Analysis for Enforcement

Samples".

8. The active and passive solvent losses from spray gun

cleaning systems shall be determined using South Coast

Air Quality Management District's "General Test Method

for Determining Solvent Losses from Spray Gun Cleaning

Systems" dated October 3, 1989. The test solvent for

this determination shall be any lacquer thinner with a

minimum vapor pressure of 105 mm Hg at 20o C. The

minimum test temperature shall be 15o C.

F. Violations

Failure to comply with any provision of this rule, including

submittal of control plans and maintenance of records, is a

violation of this rule.

G. Definitions

1. "Active Solvent Losses": Emissions losses during all

steps of a spray gun equipment cleaning operation

expressed as grams of solvent loss per cleaning cycle.

2. "Aircraft or Aerospace Vehicle": A fabricated part,

assembly of parts or completed unit of any aircraft,

helicopter, missile or space vehicle.

3. "Air-Dried Coating": Any coating which is not heated

above 90oC (194oF) for the purpose of curing or drying.

4. "Baked Coating": Any coating which is cured or dried

in an oven where the oven air temperature exceeds 90oC

(194oF).

5. "Camouflage Coating": A coating that functions to

conceal equipment from detection.

6. "Coating": A material applied to a metal surface as

a film to beautify and/or protect the surface.

7. "Control Device Efficiency": The percentage by

weight of ROC entering a control device that is not

emitted to the atmosphere.

8. "Electric Insulating Varnish": A non-convertible-

type coating applied to electric motors or components

of electric motors.

9. "Electrostatic Application": A sufficient charging

of atomized paint droplets to cause deposition

principally by electrostatic attraction.

10. "Etching Filler": A coating that contains less

than 23 percent solids by weight and at least 1/2

percent acid by weight, and is used instead of a

pretreatment wash primer on a metal substrate prior to

a primer.

11. "Exempt Organic Compounds": As defined in Rule 2,

Definitions.

12. "Extreme Performance Coating": Any coating except a

zinc filled primer, a laboratory furniture coating, or

a pretreatment coating that is exposed to any of the

following conditions:

a. Industrial-grade detergents, cleaners, or

abrasive scouring agents.

b. Unprotected shipboard conditions.

c. Frequent or chronic exposure to salt water,

corrosives, caustics, acids, or oxidizing

chemicals.

d. Other similar or more harsh environmental

conditions as determined in writing by the APCO.

13. "Grams of ROC per liter of coating, less water and

less exempt organic compounds": The ROC content in

coatings excluding water and exempt organic compounds

calculated as follows:

Grams of ROC per Liter of Coating Ws-Ww-Wes

Less Water and Less Exempt Organic Compounds =

Vm-Vw-Ves

where Ws = Weight of volatile compounds (grams)

Ww = Weight of water (grams)

Wes = Weight of exempt organic compounds

(grams)

Vm = Volume of material (liters)

Vw = Volume of water (liters)

Ves = Volume of exempt organic compounds

(liters)

14. "Grams of ROC per liter of material": The weight of

ROC per volume of material calculated as follows:

Grams of ROC per liter

of Material = Ws - Ww - Wes

------------

Vm

Where: Ws = Weight of volatile compounds (grams)

Ww = Weight of water (grams)

Wes = Weight of exempt organic compounds

Vm = Volume of material (liters)

15. "Gun Washer": Electric or pneumatic equipment

designed to clean coating application equipment while

enclosing cleaning liquids and associated vapors.

16. "Hand Application Methods": The application of

coatings by nonmechanical hand-held equipment including

but not limited to paint brushes, hand rollers,

caulking guns, trowels, spatulas, syringe daubers, rags

and sponges.

17. "Heat Resistant Coating": Any applied coating that

during normal use must withstand a temperature of at

least 204o C (400o F).

18. "High Gloss Coating": Any coating which when tested

in accordance with ASTM Test Method D523-89 has a

reflectance of 85 percent or more on a 60 degree meter.

19. "High Performance Architectural Coating": Any

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.

20. "High Temperature Coating": Any applied coating

that during normal use must withstand a temperature of

at least 538 oC (1000 oF).

21. "High Volume Low Pressure Application (HVLP)":

Spray equipment which uses a high volume of air

delivered at pressures between 0.1 and 10 psig and

which operates at a maximum fluid delivery pressure of

50 psig.

22. "Leak": The dripping of three or more drops per

minute of ROC containing liquids.

23. "Low Emissions Spray Gun Cleaner": Any properly

used spray equipment cleanup device which has passive

solvent losses of no more than 0.6 grams per hour and

has active solvent losses of no more than 15 grams per

operating cycle as determined by the test method in

Subsection E.8.

24. "Metallic Coating": Any coating, except zinc filled

primer, which contains 5 grams of metal particles per

liter of coating, as applied, where such particles are

visible in the dried film.

25. "Metal Part or Product": Any component or complete

unit fabricated from metal, not including stationary

structures or their appurtenances, marine vessel

exteriors, aerospace vehicles and components, and motor

vehicles and mobile equipment.

26. "Mold-Seal Coating": The initial coating applied to

a new or repaired mold to prevent products from

sticking to the mold.

27. "Operation": The coating, surface preparation, and

cleaning of metal parts or products and any associated

activities including but not limited to the cleaning of

coating application equipment.

28. "Pan Backing Coating": Any coating applied to the

surface of pots, pans, or other cooking utensil that

are exposed directly to a flame or other heating

elements.

29. "Passive Solvent Losses:" Emissions resulting

from natural vaporization of solvent from spray gun

cleaning equipment not being used in a cleaning cycle.

30. "Powder Coating": Any coating applied as fine

particle solids with less than 4 percent by weight ROC

or other liquid carriers.

31. "Pretreatment Wash Primer": Any coating which

contains at least one half percent acid by weight to

provide surface etching, corrosion resistance,

adhesion, and ease of stripping when applied to a metal

surface.

32. "Reactive Organic Compounds": As defined in Rule 2,

Definitions.

33. "ROC Content": For coatings, ROC (VOC) content

means the grams of ROC per liter of coating, less water

and less exempt organic compounds. For liquid cleaning

materials and other ROC containing materials, ROC

content means the grams of ROC per liter of material.

34. "Silicone Release Coating": Any coating which

contains silicone resin and functions to prevent food

from sticking to metal surfaces such as baking pans.

35. "Solar Absorbent Coating": Any coating which has as

its prime purpose the absorption of solar radiation.

36. "Substrate Surface Cleaning": Cleaning of a

substrate to remove dirt, oils, and other contaminants.

Substrate surface cleaning is typically done prior to

the application of surface coatings, adhesive bonding

materials, or sealants.

37. "Transfer Efficiency": The ratio of the weight of

coating solids adhering to the part being coated to the

weight of coating solids used in the application

process expressed as a percentage.

38. "Vacuum Metalizing Coating": Any undercoat applied

to a substrate prior to application of a metal film, or

an overcoat applied directly to the metal film.

39. "Volatile Organic Compounds (VOC)": Reactive organic

compounds (ROC).

40. "Zinc Filled Primer": Any coating which has an

elemental zinc content of not less than 240 grams/liter

(2.0 pounds per gallon) as applied.