SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Rule 4602 (Motor Vehicle Assembly Coatings)

September 17, 2009

Prepared by: Anna Myers, Air Quality Specialist

Reviewed by: Dustin Brown, Senior Air Quality Engin eer Joven R. Nazareno, Senior Air Quality Engineer George Heinen, Rule Development Supervisor Errol Villegas, Planning Manager

I. SUMMARY

A. Reasons for Rule Development and Implementation

The United States Environmental Protection Agency ( EPA) and the California Air Resources Board (ARB) classified the San Joaquin Va lley Air Basin (SJVAB) as

a serious and severe non-attainment area for the fe deral and state ozone standards, respectively. Clean Air Act (CAA) secti on 172 (2)(1) provides that state implementation plans (SIPs) for nonattainment areas must include reasonably available control technology (RACT), for sources of emissions. Section 182 (b)(2) provides for certain nonattainme nt areas, States must revise

their SIPs to include RACT for sources of VOC emiss ions covered by all Control Techniques Guidelines (CTG) documents issued after November 15, 1990 and prior to the area’s date of attainment.

CAA section 183(e) directs EPA to list for regulati on those categories of products that account for at least 80 percent of the VOC emi ssions, on a reactivityadjusted basis, from consumer and commercial produc ts in areas that violate the national ambient air quality standards (NAAQS) for ozone (i.e., ozone nonattainment areas). EPA issued the list on March 23, 1995, and continues to revise the list periodically. EPA promulgated a ne w CTG for Automobile and Light-Duty Truck Assembly Coatings (EPA-453/R-08-00 6), and a new CTG for Miscellaneous Metal and Plastic Parts Coatings (EPA -453/R08/003). CAA section 182(b)(2) requires that a CTG issued betwee n November 15, 1990, and the date of attainment include the date by which St ates subject to section 182(b) must submit SIP revisions in response to the CTG. EPA is providing, in said CTG, a one-year period for the required submittal.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 B. Description of Project

The purpose of this rule amending project is to ame nd Rule 4602 (Automobile and Light-Duty Truck Assembly Coatings) to implemen t RACT requirements as recommended in two CTGs promulgated by EPA in Septe mber of 2008, as required by the CAA. The two CTGs are for Automobi le and Light-Duty Truck Assembly Coatings (EPA-453/R-08-006), and for Misce llaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003).

In developing a CTG, EPA, among other things, evalu ates the sources of VOC emissions from application processes and the availa ble control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recomm endations for RACT for motor vehicle assembly coatings. EPA considers the CTG to be presumptive RACT standards (63 FR 15015, 3/27/98), therefore, t he rule will be considered RACT after amendments to include the latest CTG req uirements.

II. BACKGROUND

Originally, Rule 4602 was Motor Vehicle and Mobile Equipment Coating Operations, and provided regulatory language pertai ning to that source category. Rule 4602 was retired on January 1, 2009 when a Rul e 4612 Motor Vehicle and Mobile Equipment Coating Operations – Phase II beca me effective. Rule 4602 will now be amended into Motor Vehicle Assembly Coa tings.

CTG for Automobile and Light-Duty Truck Assembly Co atings The Source Category for Automobile and Light-Duty T ruck Assembly Coatings includes any person who applies VOC-containing coat ings to automobiles and light-duty trucks during the assembly process, and associated solvent cleaning

activities.

This CTG provides control recommendations for reduc ing VOC emissions stemming from the use of coatings in automobile and light-duty truck assembly coating operations. The automobile and light-duty truck assembly coatings product category under section 183(e) of the CAA in cludes the primary coatings that applied to the following:

• new automobile or new light-duty truck bodies, or body parts for new automobiles or new light-duty trucks;

• other parts that are coated along with these bodie s or body parts; and

• additional coatings applied during the vehicle ass embly processSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Coatings applied during the motor vehicle assembly process include glass bonding primer, adhesives, cavity wax, sealer, coat ings most commonly applied at motor vehicle assembly plants. However, this ca tegory also includes coatings used in facilities that perform these coating opera tions on a contractual basis.

The automobile and light-duty truck assembly coatin gs product category under Section 183(e) of the CAA includes the primary coat ings applied to new automobile or new light-duty truck bodies, or body parts for new automobiles or new light-duty trucks, and other parts coated along with these bodies or body parts. The category also includes additional coati ngs applied during the vehicle assembly process. The 183(e) category also include s coatings used in facilities that perform these coating operations on a contract ual basis, but does not include coatings used at plastic or composites mold ing facilities as described in the Surface Coating of Automobiles and Light-Duty T rucks NESHAP (40 CFR part 63, subpart III).

Automobile and light-duty truck assembly coating fa cilities may have separate coating lines on which coatings are applied to othe r parts intended for use in new automobiles or new light-duty trucks (e.g., applica tion of spray primer, color and clear coat to fascia or bumpers) or to aftermarket repair or replacement parts for automobiles or light-duty trucks. The separate coa ting of these other parts and aftermarket or replacement parts is included in the Miscellaneous Metal Products and Plastic Parts Coatings categories under Section 183(e) and covered in the CTG for those categories. However, this rule-amend ing project includes those coatings into Rule 4602.

CTG for Miscellaneous Metal and Plastic Parts Coati ngs EPA recommends that states consider structuring the ir RACT rules to provide facilities that coat bodies and/or body parts for n ew heavier vehicles with the option of meeting either RACT requirements for the automobile and light-duty truck coating category or the RACT requirements for the miscellaneous metal products or plastic parts coating categories. Heav ier vehicles include all vehicles

that meet the definition of the term “other motor v ehicles”, as defined by 40 CFR § 63.3176 (NESHAP for Surface Coatings of Automobil es and Light-Duty Trucks), as presented below:

§ 63.3176 Other motor vehicle means a self-propelled vehicle designed for transporting persons or property on a street or highway that has a gross vehicle weight rating over 8,500 pounds.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Heavier vehicles coatings are included in the Misce llaneous Metal Products and Plastic Parts Coatings categories under section 183 (e) and are therefore

covered in the CTG for Miscellaneous Metal and Plas tic Parts Coatings. EPA notes, that some automobile and light-duty truck as sembly coating facilities also coat new heavier vehicle bodies or body parts for n ew heavier vehicles. The new heavier vehicles bodies or body parts for new heavi er vehicles may be coated using the same equipment and materials as those use d to coat new automobile and light-duty truck bodies or body parts for new a utomobiles and light-duty trucks. Some facilities that coat only new heavier vehicle bodies or body parts for new heavier vehicles have paint shops that are designed and operated in the same manner as paint shops that are used to coat ne w automobile and light-duty truck bodies and body parts for new automobiles and light-duty trucks. The permit requirements for these heavier vehicle paint shops are often structured in the same way as permit requirements for automobile and light-duty truck paint shops.

Providing facilities that coat bodies and/or body p arts for new heavier vehicles with the option of meeting the state RACT requireme nts for the automobile and light-duty truck coating category will provide for consistency with existing permit requirements and simplify compliance demonstration requirements for these

facilities. EPA believes that facilities that choo se this alternative will achieve at least equivalent, if not greater, control of VOC em issions.

Like automobile and light-duty truck assembly coati ng facilities, facilities that coat bodies and/or body part for new heavier vehicles ma y have separate coating lines on which coatings are applied to other parts intended for use in new heavier vehicles, or to aftermarket repair or replacement p arts for heavier vehicles. The separate coating of these other parts and aftermark et or replacement parts is

included in Miscellaneous Metal Products and Plasti c Parts Coatings categories under section 183(e) and covered in the CTG for tha t category. EPA recommends that state RACT rules provide facilities that coat bodies and/or body parts for new heavier vehicles with the option of m eeting either the state RACT requirements for automobile and light-duty truck co atings or the state RACT requirements for miscellaneous metal products or pl astic parts coatings. States that choose to provide this option may also want to evaluate, whether it is appropriate to give these facilities the option of having their separate coating of other parts and aftermarket repair or replacement p arts.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 District staff believes that it is more appropriate to incorporate the Miscellaneous Metal Products and Plastic Coatings CTG standards f or facilities that coat bodies and/or body parts for new heavier vehicles into the draft amendments to Rule 4602. It is important to mention that District sta ff’s intent is to make Rule 4602 an assembly line coating operations rule in contrast w ith Rule 4612, which is a motor vehicle and mobile equipment coating refinish ing operations rule. Based on the District’s permit database, there is no heav y vehicle assembly line coating operations currently operating within the San Joaqu in Valley.

EPA has evaluated the sources of VOC emissions and the available control approaches for addressing these emissions. Costs o f emission control options

have also been evaluated. Based on these evaluatio ns, and the most currently available data, EPA establishes presumptive RACT by promulgating the CTG.

III. DISCUSSION

A. Process Description

The coating process for automobiles and light-duty truck assembly lines consists of several processes including surface preparation, priming operations, topcoat operations, final repair operations, and cleaning a ctivities. The following is a discussion of each of these processes.

Surface Preparation Surface preparation occurs before coatings are appl ied. During this preparation stage, the body of an assembled motor vehicle under goes anticorrosion operations. During this stage, any plastic parts t o be finished with the body are

installed on the vehicle.

Priming Operations Priming operations begin in order to prepare the bo dy for finishing by applying various layers of coatings designed to protect the metal surface from corrosion and assure good adhesion of subsequent coatings.

An electrodeposited primer (EDP) coating is applied to the body using a method in which a negatively charged motor vehicle body is immersed in a positively charged bath of waterborne electrodeposition primer . The coating particles are attracted toward the body and attach onto the body surface, creating a strong bond between the coating and the body to provide a durable coating. Once the coating application deposition is completed, the bo dy is rinsed in a succession of individual spray and/or immersion rinse stations an d then dried with an automatic air blow-off. Following the rinsing and air blow o ff stage, the deposited coating is cured in an electrodeposition-curing oven.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 After curing, spot-welding joints to improve waterp roof sealing. After sealing, the body proceeds to the anti-chip booth. Anti-chip co atings protect the vulnerable areas of the body. Next, a primer-surfacer coating is applied. The purpose of the primer-surfacer coating is to provide “filing” or hide minor imperfections in the body, provide additional protection to the vehicle body, and bolster the appearance of the topcoats. Primer-surfacer coatin gs are applied by spray application in a water-wash spray booth. Following application of the primersurfacer, the body is baked to cure the film, minim ize dirt pickup, and reduce processing time.

Topcoat Operations The spray application of the topcoat usually consis ts of a basecoat (color) and a clearcoat. The purpose of the clearcoat is to add luster and durability to the vehicle finish and protect the total coating system against solvents, chemical agents, water, weather, and other environmental eff ects.

After the topcoat is applied, the motor vehicle bod y or body parts proceed to a flash-off area, where a certain level of solvent ev aporation occurs. This step prevents bubble formation during curing in the bake oven. After flash-off, the motor vehicle bodies or body parts are then dried, or cured, in bake ovens.

Final Repair Operations Final repair means the operations performed and coa ting(s) applied to assembled motor vehicles or to parts that are not y et on a completely assembled motor vehicle to correct damage or imperfections in the coating. The curing of the coatings applied in these operations occurs at a lower temperature than that used for cuing primer-surfacer and topcoat. This l ower temperature cure avoids the need to send parts that are not yet on a comple tely assemble d vehicle through the same type of curing process used for pr imer-surfacer and topcoat and is necessary to protect heat sensitive componen ts on completely assembled

motor vehicles.

Cleaning Activities Cleaning materials use includes the removal of coat ing residue or other unwanted materials from equipment related to the co ating operations such as spray guns, transfer lines, tanks, and the interior of spray booths. These cleaning materials are typically mixtures of organi c solvents.

Work practices are widely used throughout the motor vehicle manufacturing industry to reduce VOC emissions from cleaning oper ations. These measures include covering mixing tanks and storing solvents and solvent soaked rags and wipes in closed containers. Another method is the use of low-VOC content or low vapor pressure cleaning materials. However, th ere is insufficient information to correlate VOC content or vapor pressure to speci fic cleaning steps.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 B. Available Controls and Regulatory Approaches

1. Sources of VOC Emissions There two primary sources of VOC emissions from mot or vehicle coating operations: evaporation of VOC from the coatings, a nd evaporation of VOC from the cleaning materials. VOC emissions depend of VO C content, transfer efficiency, and the presence and extent of VOC cont rol equipment. Liquid coatings are reformulated to lower VOC content. VO C contents and emission

rates for solvent-borne and waterborne materials al so have overlapping ranges.

Coatings The VOC emissions from coating application occur wh en solvent evaporates from the coating during application to the vehicle part or body. The transfer efficiency (ratio of the amount of coating solids d eposited onto the surface of the object to the total amount of coating solids spraye d while applying the coating to the object) of a coating application method affects the amount of VOC emitted during coating application. A coating application method is more efficient in transferring coatings to the substrate will reduce the volume of coatings (and therefore solvents) needed per given amount of prod uction, thus reducing VOC

emissions.

Industry has steadily moved to lower VOC content co atings including powder coatings, waterborne coatings, and higher solids so lvent-borne coatings. The utilization of these alternative coatings in conjun ction with efficient spray application equipment, such as electrostatic spray, is the primary method currently used at motor vehicle assembly coating op erations to reduce VOC emissions from the coatings. In addition, many fac ilities have also employed partial spray booth controls by venting spray booth emissions, principally from automated spray zones, through an add-on control de vice such as an oxidizer or hybrid control system.

Some motor vehicle assembly plants use powder anti- chip and primer-surfacer coatings. Powder coating produces minimal amounts of VOC emissions. Powder coating delivery systems, in most cases are via electrostatic spray. No VOC emissions are associated with the application o peration of powder coatings because they are dry particles. Depending on the p owder formulation, some VOC emissions may occur during the heating of the p owder during curing. In any event, any VOC emissions from the heating of po wder coatings would generally be much less than the VOC emissions from the heating of liquid coatings during the curing operations. Powder coat ing applications are best suited for long production runs of consistently siz ed parts without color changes. Powder anti-chip and primer-surfacer coatings are u sed at some assembly plants.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Waterborne coatings produce less VOC emissions than conventional solventborne coatings primarily because a large portion of the organic solvent carrier is replaced with water. Almost every motor vehicle as sembly plant uses waterborne electrodeposition primers. Waterborne p rimer-surfacer and

waterborne basecoat and used at some motor vehicle truck assembly plants. Waterborne primer-surfacer and waterborne basecoat are applied by a combination of manual and automatic, and electrosta tic and non-electrostatic spray techniques.

Higher solids solvent-borne coatings contain more s olids than “conventional” (pre-1980) solvent-borne coatings. These coatings contain less organic solvent VOC, per unit volume, of solids than conventional s olvent-borne coatings. Thus, less VOC emissions escape during coating preparatio n, application, and curing to deliver a given amount of coating solids. Highe r solids primer-surfacer and basecoat application include a combination of manua l and automatic, and electrostatic and not-electrostatic spray technique s.

Additional VOC emissions occur in the flash-off are a after coatings are applied, and in baking ovens where drying and curing occur.

Cleaning Materials Cleaning materials are another source of VOC emitte d by motor vehicle surface coating operations. The VOC escape when solvents e vaporate from the cleaning materials during use.

Cleaning materials with low-VOC composite vapor pre ssure and/or low-VOC content generate less VOC emissions than materials with higher VOC vapor pressure and/or content. The VOC composite vapor p ressure of a cleaning material is a weighted average of the vapor pressur e of the VOC components of that cleaning material. The vapor pressure of each VOC component is weighted by the mole fraction of that VOC component in the c leaning material, including non-VOC components such as water or exempt compound s. Water and exempt compounds thereby reduce the VOC composite vapor pr essure of cleaning materials in which they are present. Although use of lower vapor pressure cleaning materials may reduce VOC emissions, insuff icient information is available to correlate cleaning material vapor pres sure to specific cleaning steps in the motor vehicle surface coating industry. Sim ilarly, cleaning materials with low VOC content would generate less VOC emissions t han materials with high VOC content; however, insufficient information is a vailable to correlate cleaning material VOC content to specific cleaning steps in this industry.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 2. Available Controls for VOC Emissions There are two general emission control techniques f or reducing VOC emissions: pollution prevention measures, and emission capture and add-on control systems. Pollution prevention is the most prevalen t control technique, followed by add-on control systems. Provided below is a sum mary of these control techniques.

a. Pollution Prevention Measures Pollution prevention measures include product subst itution/reformulation, work practice procedures, and equipment substitution.

Product Substitution/Reformulation One pollution prevention measure is to substitute h igher-solvent coatings with coatings containing little or no solvents. These c oatings include waterborne coatings, higher solids coatings, and reactive coat ings. Conversion to waterborne coatings (for example) can lower VOC emi ssions greatly.

Work Practices Work practice procedures are physical actions inten ded to affect emission reductions. Work practice procedures are tailored to an industry, and may vary from a few manual operations to a complex program. Work practices include effectively controlling material preparation, maxim izing the amount of coating transferred to the substrate by application methods with higher transfer efficiencies and improved spray technique, and usin g proper equipment maintenance procedures.

Equipment Substitution Using more efficient application equipment reduces VOC emissions. Conventional air atomized spray application systems utilize high atomizing air pressure with typical transfer efficiencies of 25 t o 40 percent. More modern technologies, such electrostatic and HVLP spray equ ipment, achieve high transfer efficiencies, up to 90 percent, depending on the product shape, size, and substrate. The use of efficient coating applicatio n equipment reduces VOC emission by increasing the coating transfer efficie ncy. Since the 1970’s, spray equipment used to apply motor vehicle assembly coat ings has become increasingly automated.

b. Emission Capture and Add-on Control Systems In addition to pollution prevention measures, VOC e missions from motor vehicle assembly coating application operations can be redu ced by the use of capture systems, in conjunction with add-on control systems that either destroy or recover the VOC in the exhaust streams. Many facil ities control the exhaust from bake ovens. Some operators have employed partial s pray booth controls by venting spray booth emissions, principally from aut omated spray zones, through an add-on control device such as an oxidizer or hyb rid (concentrator followed bySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 an oxidizer) control system. Spray booths typicall y exhaust a high volume of air

with a low concentration of VOC with can result in a high cost of control. Although capture systems and add-on control devices are available to facilities they are generally not used when low VOC coatings a nd alternative application

methods are available to reduce VOC emissions.

Capture Systems Capture systems collect solvent-laden air from proc ess vents (e.g., spray booth, flash-off or bake oven vents) and direct the captur ed air to a control device. The majority of VOC emissions from motor vehicle assemb ly coating occur in the spray booth. The collected emissions are ducted fr om the spray booth directly to the control device. Similarly, flash-off area or b ake oven exhaust is ducted directly to the control device.

The design of the capture system can greatly contri bute to the overall VOC control efficiency. An efficient capture system ma ximizes the capture of emissions and minimizes the capture of dilution air . Facilities may combine several captured VOC-laden streams and duct them to a single control device.

Add-on Control Systems

Add-on controls reduce the amount of VOC emissions by either destruction or recovery with or without recycling of VOC emission in the exhaust streams. Two categories of add-on control devices typically used by motor vehicle assembly coatings operations include combustion and recovery . While many control devices are available to reduce VOC emissions, the following summary covers

those control devices in use in motor vehicle surfa ce coating operations: oxidation and hybrid systems (concentrator followed by an oxidizer).

Oxidation Oxidation destroys VOC emissions in an exhaust stre am by exposing the stream to an oxidizing atmosphere at high temperatures. O xidizers can control bake oven exhaust emissions, and may be of thermal or ca talytic design and combust VOC-container exhaust streams. Catalytic oxidizers are similar to thermal oxidizers but employ a catalyst to aid in the oxida tion reaction. As a result, catalytic oxidizers operate at lower combustion tem peratures relative to that required in thermal oxidizers. Both types of oxidi zers generally utilize either regenerative or recuperative techniques to preheat inlet gas in order to decrease energy costs associated with high oxidation tempera tures. They may also use primary or secondary heat recovery to reduce energy consumption. Oxidizers achieve destruction efficiencies of greater than 95 % as applied to coating application operations with high and constant conce ntrations of VOC.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Hybrid Systems Hybrid systems consist of a concentrator followed b y an oxidizer. Hybrid systems control spray booth exhaust emissions. The concentrator is typically a

carbon or zeolite rotor. The concentrator reduces the volume and increases the

VOC concentration of the inlet stream to the oxidiz er.

Adsorption Adsorption occurs when the unbalanced molecular forces on the surface of solids (the adsorbant) attract and retain gases and partic ulate matter that encounter the solid. Several materials are widely used as the ad sorbent, such as activated carbon, organic resin polymer, and inorganic materi als. Each has substantial surface area per unit volume.

In a typical carbon adsorber, VOC-laden air is pass ed through a regenerable fixed bed of granular activated carbon (the adsorbe nt). Adsorber beds are typically operated in parallel to avoid interruptio n of VOC control. In this arrangement, when the adsorption capacity of one be d is exhausted, it can be removed from service, and a second adsorber bed can be put into service, ensuring that a control device is operating at all times. The spent carbon bed in the first adsorber bed is then regenerated and can be put into service again. Carbon adsorption systems can achieve control devic e efficiencies greater than 95 percent.

In contrast to combustion, carbon adsorption does n ot destroy the VOC it

removes from the air stream. Carbon adsorbers are thermally regenerated, usually by passing steam through the carbon beds. The VOC are removed from the carbon (desorbed) and transferred to the steam. The VOC-containing steam is then condensed, and the VOC solvent is separated from the water. Regeneration can also be achieved with hot air. Ho t-air regeneration is generally used when dealing with water-soluble solvents.

Carbon adsorbers are most suitable for solvents tha t are immiscible with water, such as toluene and xylene, but are not recommended for water-soluble VOC, such as methyl ethyl ketone and methyl isobutyl ket one. In the case where a water-soluble VOC is present, the water vapor will be adsorbed and desorbed along with the VOC vapor, and the VOC may require s ubsequent purification if it is to be reused. The presence of solid particles o r polymerizable substances in the inlet air stream to a carbon adsorber may requi re pretreatment of the inlet air. In addition, adsorption is usually used for exhaust streams at ambient temperature up to approximately 38°C (100°F). Ther efore, cooling and dehumidification may also be required as pretreatme nt in some cases.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Work Practices Work practices are physical actions intended to aff ect emission reductions, and are specifically tailored to each industry. Work p ractices vary from a few manual operations to a complex program. Coating waste gen erated during material preparation, coating application, and equipment cle aning. When coating waste is reduced, overall VOC emissions are reduced. Coatin g waste may be reduced through work practices by effectively controlling m aterial preparation and using proper equipment maintenance procedures.

4. Available Controls for VOC Emissions from Clean ing Materials Pollution prevention measures from cleaning materia ls and activities include work practices, and product substitution or reformulatio n. Add-on control technologies are not in use specifically for reducing VOC emissi ons from cleaning operations, however, if cleaning operations are performed withi n a capture system that is ducted to an add-on control system, the VOC emissio ns from the cleaning operations would be reduced by the add-on control.

a. Work Practice Procedures Work practice procedures reduce VOC emissions durin g cleaning operations by reducing the amount of VOC that can evaporate due t o exposure to air. Work practice procedures include the following:

• Cover mixing, storage, and waste vessels for VOC-c ontaining cleaning materials, except when adding, removing, or mixing contents;

• Convey and store VOC-containing cleaning materials and waste in closed containers or pipes;

• Minimize spills; and

• Minimize VOC emissions during cleaning operations.

b. Product Substitution/Reformulation Product substitution or reformulation is another ty pe of pollution prevention measures. Reducing the composite VOC vapor pressur e or VOC content of cleaning materials used reduces VOC emissions from cleaning operations. However, there is insufficient information availabl e to correlate VOC content or vapor pressure to specific cleaning steps.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 IV. CURRENT AND PROPOSED REGULATIONS

A. Current Regulations

District Rule 4602 is currently retired, but when i t was active it set limits for VOC emissions from the finishing and refinishing of Gro up I Vehicles and Group II Vehicles and Equipment, and from the organic solven t cleaning, and the storage and disposal of solvents and waste solvent material s associated with such finishing and refinishing.

Existing State and Local VOC Requirements

The following discussion is a summary of EPA action s, as well as State and local regulations, which address VOC emissions from motor vehicle assembly coating

processes.

1. The 1977 CTG In 1977, EPA issued a CTG document entitled "Contro l of Volatile Organic Emissions from Existing Stationary Sources Volume I I: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks. (EPA-450/2-77-008) The 1977 CTG and subsequent implementation guidance provided RACT recommendations for controlling VOC emissions from automobile and light-duty truck assembly surface coating operations.

2. The 1980 NSPS In 1980, EPA promulgated an NSPS for surface coatin g of automobile and lightduty trucks (40 CFR part 60 subpart MM). The NSPS established that emission limits be calculated on a monthly basis for each pr ime coat operation, guide coat. (primer-surfacer) operation and topcoat operation l ocated in an automobile or light-duty truck assembly plant constructed, recons tructed, or modified after October 5, 1979 (Table 2). The NSPS does not apply to plastic body component coating operations or to all-plastic automobile or light-duty truck bodies coated on separate coating lines. The NSPS limits and the 19 77 CTG recommendations for primer-surfacer and topcoat cannot be directly compared because of differences in the compliance period (monthly for t he NSPS limits and daily for the CTG recommendations) and how transfer efficienc y is considered.

3. The 2004 NESHAP In 2004, EPA promulgated the National Emissions Sta ndards for Hazardous Air Pollutants: Surface Coating of Automobile and Light -Duty Trucks, 40 CFR, part 63, subpart IIII. The NESHAP covers all equipment used to apply, dry, or cure coatings to new automobile or light-duty truck bodi es or body parts; all storage containers and mixing vessels; and all manual and a utomated equipment and containers used for conveying coatings, thinners, c leaning materials, and waste. The 2004 NESHAP for automobile and light-duty truck assembly coatingSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 imposed organic HAP emission limitations calculated on a monthly basis for existing sources, with more stringent limits for ne w sources. The NESHAP also sets emission limits for coatings not included in t he CTG or NSPS, including glass-bonding primer, glass bonding adhesive, and some coatings and thinners. The 2004 NESHAP also specif ied work practices to minimize organic HAP emissions from the storage, mi xing, and conveying of coatings, thinners, cleaning materials, and from ha ndling waste materials generated by the coating operation.

4. Existing State and Local VOC Requirements

Fourteen States and one California air district hav e regulations that control VOC emissions from motor vehicle assembly coating. Mos t of the state rules have

limits that are consistent with the 1977 CTG recomm ended limits.

B. CTG Recommended Rule Requirements

1. CTG for Automobile and Light-Duty Truck Assembl y Coatings

The CTG for Automobile and Light-Duty Truck Assembl y Coatings provides control recommendations for reducing VOC emissions from automobile and lightduty truck assembly coating operations. In terms o f applicability, EPA recommends the control approaches discussed in the CTG apply to facilities

where the total actual VOC emissions from all misce llaneous industrial adhesive application processes, including related cleaning a ctivities, at that facility are equal to or exceed 15 lb/day, (3 tons per 12-month rolling period) before

consideration of controls.

CTG recommendations include VOC emission limits for coating operations, and work practices for storage and handling of coatings , thinners, coating waste materials and cleaning materials. The following is a summary of recommendations for coating operations and cleaning materials used in automobile and light-duty truck assembly coating op erations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 A. Coatings

VOC emission limits are recommended to reduce VOC e missions from the coatings during the coating operations. For all th e operations, except for final repair, the recommended limits are based on data su pplied by the Alliance of Automobile Manufacturers member companies and non-m ember companies in 2008. For final repair operations, no information was presented in the industry submittals. Therefore, EPA chose to recommend the limits for final repair

recommended in the 1977 CTG. An alternative emissi on limit for combined primer-surfacer and topcoat applications is recomme nded because in some facilities these processes are becoming indistingui shable from each other.

Table 1. Recommended VOC Limits for Motor Vehicle Assembly Coatings

Assembly Coating Process Recommended VOC Emission L imit

When solids

turnover ratio ( R T )> 0.16: When

0.040< R T

<0.160: When

R T <0.040: Electrodeposition primer (EDP) operations (including application area, spray/rinse stations, and curing oven) 0.084 kg VOC/liter (0.07 lb/gal) coating solids applied. 0.084x350 0.160- R T kg VOC/liter (0.084X350

0.160- R T x8.34 lb/gal) coating solids applied No VOC

emission

limit

Primer-surfacer operations(including application area, flashoff area, and oven) 1.44 kg of VOC/liter of deposited solids (12.0 lbs VOC/gal deposited solids) on a daily weighted average basis as determined by following the procedures in the revised Automobile topcoat

Protocol.

Topcoat operations (including application area, flash-off area, and oven) 1.44 kg of VOC/liter of deposited solids (12.0 lbs VOC/gal deposited solids) on a daily weighted average basis as determined by following the procedures in the revised Automobile topcoat

Protocol.

Final repair operations 0.58 kg VOC/liter (4.8 lb VOC/gallon of coating) le ss water and less exempt solvents on a daily weighted average basis or as an occurrence weighted

average.

Combined primer-surfacer and topcoat operations 1.44 kg of VOC/liter of deposited solids (12.0 lbs VOC/gal deposited solids) on a daily weighted average basis as determined by following the procedures in the revised Automobile topcoat

Protocol.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Table 2 presents the recommended VOC emissions limi ts for miscellaneous materials used at motor vehicle assembly coating fa cilities. Limits are expressed as grams of VOC per liter of coating excluding wate r and exempt compounds, as applied.

Table 2. VOC Content Limits for Miscellaneous Mate rials used for

Motor Vehicle Assembly Coatings

Material Recommended VOC Limit (Grams of VOC per liter of material)
Glass bonding primer 900

Adhesive 250 Cavity wax 650

Sealer 650

Deadener 650 Gasket/ gasket sealing material 200
Underbody coating 650
Trunk interior coating 650

Bedliner 200
Weatherstrip adhesive 750
Lubricating wax/compound 700

EPA recommends that the VOC emission limits not app ly to materials supplied in containers with a net volume of 16 ounces or less, or a net weight of one pound

or less. EPA also recommends that the VOC content of coatings, other than reactive adhesives, used at motor vehicle coatings assembly coating facilities be determined using EPA Method 24. The procedure for reactive adhesives in Appendix A of the NESHAP for surface coating of pla stic parts (40 CFR Part 63, subpart PPPP) be used to determine the VOC content of reactive adhesives. EPA recommends Districts accept manufacturer’s form ulation data in lieu of these methods. If there is a disagreement between manufacturer’s formulation data and the results of a subsequent test, the Dist rict should use the test method results unless the facility can make a demonstratio n to the District’s satisfaction

that the manufacturer’s formulation data are correc t.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4602 September 17, 2 009

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Proposed Amendments to Rule 4602 B. Work Practices for Coating-Related Activities an d Cleaning Materials Work practices are recommended to reduce VOC emissi ons from automobile and light-duty truck assembly coating-related activ ities. Specifically, EPA recommends the following work practices for storage , mixing, and handling operations for coatings, thinners, and coating-rela ted waste materials:

• store all VOC-containing coatings, thinners, and c oating-related waste materials in closed containers;

• ensure that mixing and storage containers used for VOC-containing materials are kept closed at all times except when depositing or removing these materials;

• minimize spills of VOC-containing materials;

• convey VOC-containing materials from one location to another in closed containers or pipes; and

• minimize VOC emission from cleaning of storage, mi xing, and conveying equipment.

Additionally, EPA recommends that operators develop and implement a work practice plan to minimize VOC emissions from cleani ng and from purging of equipment associated with all coating operations fo r which emission limits are recommended in this CTG. The plan should specify p ractices and procedures to ensure that VOC emissions from the following operat ions are minimized:

• Vehicle body wiping;

• Coating line purging;

• Flushing of coating systems;

• Cleaning of spray booth grates;

• Cleaning of spray booth walls;

• Cleaning of spray booth equipment;

• Cleaning external spray booth areas; and

• Other housekeeping measures (e.g., keeping solvent -laden rags in closed containers.)

The 2004 NESHAP similarly requires development and implementation of a work practice plan for reducing HAP emissions. If a fac ility covered by this CTG already has a NESHAP work practice plan in place, i nstead of creating other work practice plan to address VOC emissions, EPA re commends that he facility simply add to its NESHAP work practice plan procedu res for minimizing non-HAP VOC emissions. Most elements of the NESHAP work pr actice plan are also consistent with reducing VOC emissions. Therefore, there is no need to create another work practice plan to address VOC emissions

.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 2. CTG for Miscellaneous Metal and Plastic Parts C oatings

The CTG for Miscellaneous Metal and Plastic Parts C oatings recommends three options for controlling the VOC emissions from the coatings used by miscellaneous metal product and plastic part surfac e coating facilities. In addition to the three options for VOC control, EPA recommends work practices. District Rule 4603 Surface Coating of Metal Parts a nd Products, Plastic Parts and Products, and Pleasure Crafts addresses the CTG recommendations.

However, one section of the CTG for Miscellaneous M etal and Plastic Parts Coatings is addressed by District Rule 4602 Motor V ehicle Assembly Coatings. The portion of the CTG addressed by Rule 4602 is th e section pertaining to

Motor Vehicle Materials.

With exception of three coating standards, the VOC recommended content limits

for motor vehicle materials in the CTG for Miscella neous Metal and Plastic Parts Coatings are identical to the VOC content limits fo r miscellaneous materials addressed by the CTG for Automobile and Light-Duty Truck Assembly Coatings. Glass bonding primer, adhesive, and weatherstrip ad hesive coatings are not mentioned for heavier vehicle coatings limits in th e CTG for Miscellaneous Metal and Plastic Parts Coatings. Please see Table 2 for requirements.

C. Draft Rule Changes

Section 1.0 Purpose The purpose of this rule would be amended to reflec t the new source category this rule will apply to effective on and after the date of adoption of the amendments. The purpose will now reflect this rule is intended to limit the emissions of VOC from motor vehicle assembly coatin g operations.

Section 2.0 Applicability This section would be amended to make this rule app licable to operators who apply VOC-containing coatings to new automobiles, l ight-duty trucks, heavier vehicles, and other parts coated along with these b odies or body parts during the assembly process, and associated solvent cleani ng activities. That is to say this rule would apply to assembly plants of new mot or vehicles that have coating at the facility.

Section 3.0 Definitions

Definitions would be added and removed to reflect t he new requirements and applicability of rule language.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Section 4.0 Exemptions This section would be amended to remove previous ex emptions that do not apply to the new rule requirements and to provide a n exemption for materials supplied in containers with a net volume of 16 flui d ounces or less, or a net weight of one pound or less.

A limited exemption was added into rule language fo r operations where the total

actual VOC emissions from all motor vehicle assembl y coating operations, including related cleaning activities, at that faci lity are less than 6.5 kg/day (15 lb/day) before consideration of controls. This lim ited exemption was added to proposed rule language to make this rule more consi stent with the CTG requirements. The exemption is limited because the operator must keep records to prove that the facility is below the threshold t o be subject to VOC controls. Therefore, the operator will be subject to record k eeping requirements of Section

6.1.

Section 5.0 Requirements This section would be amended to remove all require ments from the previous version of the rule that do not apply to this rule and it’s new source category. New requirements would be added to set limits for a utomobile, light-duty truck, and heavier vehicle assembly coating operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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20 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 Section 5.1

This section would be amended to set VOC emission l imits for motor vehicle assembly coatings based on the assembly coating pro cess as presented in Table

3.

Table 3. VOC Limit for Motor Vehicle Assembly Coat ing Processes

Assembly Coating

Process Recommended VOC Emission Limit

When solids

turnover ratio (R T )>0.16: When 0.040< R T

<0.160: When R T <.040: Electrodeposition primer operations (including application area, spray/rinse stations, and curing oven) 0.084 kg VOC

/liter (0.7 lb/gal) coating solids applied 0.084x350 0.160- R T kg

VOC/liter (0.084x350

0.160- R T x 8.34 lb/gal) coating solids applied No VOC

emission limit

Primer-surfacer operations (including application area, flash off area, and oven) 1.44 kg of VOC/liter of deposited solids (12.0 lb V OC/gal deposited solids) on a daily weighted average basis as determined by following the procedures in the revis ed

Automobile Topcoat Protocol. Topcoat operations (including application area, flash-off area, and oven) 1.44 kg of VOC/liter of deposited solids (12.0 lb V OC/gal deposited solids) on a daily weighted average basis as determined by following the procedures in the revis ed

Automobile Topcoat Protocol.

Final repair operations 0.58 kg VOC/liter (4.8 lb VOC/gallon of coating) le ss water and less exempt solvents on a daily weighted average ba sis or as

an occurrence weighted average.

Combined primersurfacer and topcoat operations 1.44 kg of VOC/liter of deposited solids (12.0 lb V OC/gal deposited solids) on a daily weighted average basis as determined by following the procedures in the revis ed

Automobile Topcoat Protocol.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Section 5.1 would also establish VOC emission limit s, in grams of VOC per liter of coating excluding water and exempt compounds as applied, for miscellaneous materials used at a motor vehicle assembly coating facility.

Table 4. VOC Emission Limit for Miscellaneous Mate rials at Motor Vehicle

Assembly Coating Operations

Material VOC Emission Limit (g VOC / liter)

Glass Bonding Primer 900

Adhesive 250

Cavity Wax 650

Sealer 650

Deadener 650

Gasket/Gasket Sealing Material 200

Underbody Coating 650

Interior Coating 650

Bedliner 200 Weatherstrip Adhesive 750

Lubricating Wax/Compound 700

Three coating categories, Adhesive, Weatherstrip Ad hesive, and Glass Bonding Primer, are currently being added to the Rule 4653 (Adhesives) per the CTG for

Miscellaneous Industrial Adhesives. These new adhe sives categories would have different VOC limits than required by this rul e. Facilities subject to Rule 4653 (Adhesives) would apply new coating categories to the default category limit of 250 grams of VOC per liter of material in order to not relax rule standards. However, research of permits indicates facilities t hat would be subject to this new rule and new rule category do not have these limits or mention of these types of adhesives in current permits. Therefore, as motor vehicle assembly operations are a new category and previously unregulated limit s are proposed, this will not be a relaxation of rule requirements for new motor vehicle assembly coating operations.

Section 5.2 VOC Control System Requirements Section 5.2 would be added to provide system requir ements for a VOC control system, should the operator choose to use one. The CTG does not recommend VOC control system requirements. However, staff re commend this rule language so this rule is consistent with other District proh ibitory rules in allowing a VOC control system as a compliance option. A VOC contr ol standard of 90% is consistent with Rule 4603 (Surface Coating of Metal Parts and Products), which would be considered the default rule for metal part s and products coatings.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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22 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 Section 5.3 Coating Application Methods

This section would be amended to remove retired lan guage that is not applicable to the new source category and rule requirements. This section itemizes standards for coating application methods that alig n with CTG standards and Rule 4603 (Surface Coating for Metal Parts and Prod ucts).

Section 5.4 Organic Solvent Cleaning This section would be amended to require that solve nts used for solvent cleaning have a VOC content of equal to or less than 25 g/l of VOC. The 25 g/l requirement makes this standard as stringent as oth er prohibitory rules at the District. A section would be added to require safe solvent-cleaning methods.

This section is not in the CTG but is in the rule t o make this rule more comprehensive and to align with other District proh ibitory rules and standards.

Section 5.5 Organic Solvent Disposal and Storage No changes recommended at this time.

Sections 5.7 – 5.12 These sections would be removed from rule language, as they do not pertain to the new source category or the new rule.

Section 6.0 Administrative Requirements

Section 6.1 Recordkeeping The CTGs do not specify recordkeeping requirements. Amendments would make the recordkeeping requirements align with the recordkeeping requirements of other District prohibitory rules.

Section 6.2 Recordkeeping for VOC Emission Control Systems No changes recommended at this time.

Section 6.3 Work Practice Plan A new section would be added to rule language to re quire facilities develop and implement a work practice plan to minimize VOC emis sions from cleaning and from purging of equipment associated with motor veh icle assembly coating operations. However, if a facility is subject to t he 2004 NESHAP requirements for a work practice plan, the operator may add to t he facilities NESHAP work practice plan procedures for minimizing non-HAP VOC emissions instead of creating an entirely new plan.

Section 6.4 Compliance Statement Requirement No changes recommended at this time.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4602 Section 6.5 Test Methods This section would be amended to update it with cor rect test methods for new requirements.

Section 7.0 Compliance Schedule

This section would be added to provide a compliance date for this rule project of January 1, 2011.

V. CURRENT EMISSIONS AND EMISSION REDUCTIONS

The ARB emissions inventory database shows no basel ine emissions from motor vehicle assembly operations for any year. Research of the District’s permit

database has indicated that there are no facilities in the Valley could be subject to this rule-amending project, therefore, District staff believes that no VOC

emissions reductions will result from this rule-ame nding project.

The 2007 Ozone Plan and the 2008 PM Plan make no re ference to, or call for emission reductions from, this source category. Si nce the federal CAA requires ozone nonattainment areas to implement RACT and tha t the CTGs promulgated by EPA constitute RACT requirements, at a minimum, District staff is compelled to incorporate the CTG standards into Rule 4602.

VI. COST EFFECTIVENESS ANALYSIS

Pursuant to California Health & Safety Code Section 40920.6(a), the District is required to analyze the cost effectiveness of new r ules or rule amendments that implement Best Available Retrofit Control Technolog y (BARCT) or all feasible

measure. The draft amendments to Rule 4602 would a dd federal RACT requirements but not BARCT or all feasible measures , and are therefore not subject to the cost effectiveness analysis mandate.

VII. SOCIOECONOMIC ANALYSIS

Pursuant to California Health & Safety Code Section 40728.5 (a), an assessment of the socioeconomic impacts is not required for an y rule or regulation that only adopts a requirement that is substantially similar to, or is required by state or federal statute, regulation, or applicable formal g uidance, such as a federal CTG. Since the draft amendments to Rule 4602 implement t he CTG standards mandated by the federal Clean Air Act, a socioecono mic impact analysis is not required.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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24 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 VIII. RULE CONSISTENCY ANALYSIS

California State Health and Safety Code, Section 40 272.2, requires District staff to prepare a rule consistency analysis of Rule 4602 th at compares the elements of amendments with the corresponding elements of other District rules, federal regulations and guidelines that apply to the same s ource category or type of equipment. Preliminary analysis has indicated that none of the draft requirements of this rule would conflict with feder al rules, regulations, or policies covering similar stationary sources. District staf f will prepare a rule consistency analysis later in the rule development process.

IX. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Ac t (CEQA), District staff investigated the likely environmental impacts of th e proposed amendments to Rule

4602. Based on the lack of evidence to the contrar y, District staff has concluded that the proposed amendments to the rule will not h ave any significant adverse

effects on the environment. Staff recommends filin g a Notice of Exemption under the provisions of Public Resource Code 15061 (b) (3 ).

X. RULE DEVELOPMENT PROCESS

The draft amendments to Rule 4602 and the Draft Sta ff Report will be published

and made available to affected sources and interest ed parties for their review and comments prior to a public hearing by the Gover ning Board. Comments received from stakeholders, ARB and EPA will be eva luated, and if appropriate, incorporated into the draft amendments to the rules . District staff intends to

submit the draft rules amendments to the District G overning Board for consideration of adoption by September 2009.

XI. REFERENCES

1. Bay Area AQMD. “Rule 8-13 Light and Medium Duty Motor Vehicle Assembly

Plants”. December 1995.

2. EPA. “EPA-453/R-08-006. CTG for Automobile and Light-Duty Truck Assembly Coatings”. September 2008. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.ht m 3. South Coast AQMD. “Rule 1115 Motor Vehicle Asse mbly Line Coating Operations”. May 1995. 4. 40 CFR § 63.3176 NESHAP for Surface Coatings of Automobiles and LightDuty Trucks.