SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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 Engineer 

 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 Valley Air Basin (SJVAB) as 

a serious and severe non-attainment area for the federal and state ozone 

standards, respectively. Clean Air Act (CAA) section 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 nonattainment areas, States must revise 

their SIPs to include RACT for sources of VOC emissions 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 regulation those categories of products 

that account for at least 80 percent of the VOC emissions, on a reactivityadjusted basis, from consumer and commercial products 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 new CTG for Automobile and 

Light-Duty Truck Assembly Coatings (EPA-453/R-08-006), 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 between November 15, 1990, and 

the date of attainment include the date by which States 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. 
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B. Description of Project 

The purpose of this rule amending project is to amend Rule 4602 (Automobile 

and Light-Duty Truck Assembly Coatings) to implement RACT requirements as 

recommended in two CTGs promulgated by EPA in September of 2008, as 

required by the CAA. The two CTGs are for Automobile and Light-Duty Truck 

Assembly Coatings (EPA-453/R-08-006), and for Miscellaneous Metal and 

Plastic Parts Coatings (EPA-453/R-08-003). 

In developing a CTG, EPA, among other things, evaluates the sources of VOC 

emissions from application processes and the available control approaches for 

addressing these emissions, including the costs of such approaches. Based on 

available information and data, EPA provides recommendations for RACT for 

motor vehicle assembly coatings. EPA considers the CTG to be presumptive 

RACT standards (63 FR 15015, 3/27/98), therefore, the rule will be considered 

RACT after amendments to include the latest CTG requirements. 

II. BACKGROUND 

Originally, Rule 4602 was Motor Vehicle and Mobile Equipment Coating 

Operations, and provided regulatory language pertaining to that source category. 

Rule 4602 was retired on January 1, 2009 when a Rule 4612 Motor Vehicle and 

Mobile Equipment Coating Operations – Phase II became effective. Rule 4602 

will now be amended into Motor Vehicle Assembly Coatings. 

CTG for Automobile and Light-Duty Truck Assembly Coatings 

The Source Category for Automobile and Light-Duty Truck Assembly Coatings 

includes any person who applies VOC-containing coatings to automobiles and 

light-duty trucks during the assembly process, and associated solvent cleaning 

activities. 

This CTG provides control recommendations for reducing 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 includes 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 bodies or body parts; and 

• additional coatings applied during the vehicle assembly process 
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Coatings applied during the motor vehicle assembly process include glass 

bonding primer, adhesives, cavity wax, sealer, coatings most commonly applied 

at motor vehicle assembly plants. However, this category also includes coatings 

used in facilities that perform these coating operations on a contractual basis. 

The automobile and light-duty truck assembly coatings product category under 

Section 183(e) of the CAA includes the primary coatings 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 coatings applied during the vehicle 

assembly process. The 183(e) category also includes coatings used in facilities 

that perform these coating operations on a contractual basis, but does not 

include coatings used at plastic or composites molding facilities as described in 

the Surface Coating of Automobiles and Light-Duty Trucks NESHAP (40 CFR 

part 63, subpart III). 

Automobile and light-duty truck assembly coating facilities may have separate 

coating lines on which coatings are applied to other parts intended for use in new 

automobiles or new light-duty trucks (e.g., application 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 coating 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-amending project includes those 

coatings into Rule 4602. 

CTG for Miscellaneous Metal and Plastic Parts Coatings 

EPA recommends that states consider structuring their RACT rules to provide 

facilities that coat bodies and/or body parts for new 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. Heavier vehicles include all vehicles 

that meet the definition of the term “other motor vehicles”, as defined by 40 CFR 

§ 63.3176 (NESHAP for Surface Coatings of Automobiles 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. 
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Heavier vehicles coatings are included in the Miscellaneous Metal Products and 

Plastic Parts Coatings categories under section 183 (e) and are therefore 

covered in the CTG for Miscellaneous Metal and Plastic Parts Coatings. EPA 

notes, that some automobile and light-duty truck assembly coating facilities also 

coat new heavier vehicle bodies or body parts for new heavier vehicles. The new 

heavier vehicles bodies or body parts for new heavier vehicles may be coated 

using the same equipment and materials as those used to coat new automobile 

and light-duty truck bodies or body parts for new automobiles 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 new 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 parts for new heavier vehicles 

with the option of meeting the state RACT requirements 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 choose this alternative will achieve at 

least equivalent, if not greater, control of VOC emissions. 

Like automobile and light-duty truck assembly coating facilities, facilities that coat 

bodies and/or body part for new heavier vehicles may 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 parts for heavier vehicles. The 

separate coating of these other parts and aftermarket or replacement parts is 

included in Miscellaneous Metal Products and Plastic Parts Coatings categories 

under section 183(e) and covered in the CTG for that category. EPA 

recommends that state RACT rules provide facilities that coat bodies and/or body 

parts for new heavier vehicles with the option of meeting either the state RACT 

requirements for automobile and light-duty truck coatings or the state RACT 

requirements for miscellaneous metal products or plastic 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 parts. 
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District staff believes that it is more appropriate to incorporate the Miscellaneous 

Metal Products and Plastic Coatings CTG standards for 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 staff’s intent is to make Rule 4602 an 

assembly line coating operations rule in contrast with Rule 4612, which is a 

motor vehicle and mobile equipment coating refinishing operations rule. Based 

on the District’s permit database, there is no heavy vehicle assembly line coating 

operations currently operating within the San Joaquin Valley. 

EPA has evaluated the sources of VOC emissions and the available control 

approaches for addressing these emissions. Costs of emission control options 

have also been evaluated. Based on these evaluations, 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 activities. The following is a 

discussion of each of these processes. 

Surface Preparation 

Surface preparation occurs before coatings are applied. During this preparation 

stage, the body of an assembled motor vehicle undergoes anticorrosion 

operations. During this stage, any plastic parts to be finished with the body are 

installed on the vehicle. 

Priming Operations 

Priming operations begin in order to prepare the body 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 body is rinsed in a succession of 

individual spray and/or immersion rinse stations and then dried with an automatic 

air blow-off. Following the rinsing and air blow off stage, the deposited coating is 

cured in an electrodeposition-curing oven. 
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After curing, spot-welding joints to improve waterproof sealing. After sealing, the 

body proceeds to the anti-chip booth. Anti-chip coatings 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 coatings are applied by spray 

application in a water-wash spray booth. Following application of the primersurfacer, the body is baked to cure the film, minimize dirt pickup, and reduce 

processing time. 

Topcoat Operations 

The spray application of the topcoat usually consists 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 effects. 

After the topcoat is applied, the motor vehicle body or body parts proceed to a 

flash-off area, where a certain level of solvent evaporation 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 coating(s) applied to 

assembled motor vehicles or to parts that are not yet 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 lower temperature cure avoids 

the need to send parts that are not yet on a completely assemble d vehicle 

through the same type of curing process used for primer-surfacer and topcoat 

and is necessary to protect heat sensitive components on completely assembled 

motor vehicles. 

Cleaning Activities 

Cleaning materials use includes the removal of coating residue or other 

unwanted materials from equipment related to the coating operations such as 

spray guns, transfer lines, tanks, and the interior of spray booths. These 

cleaning materials are typically mixtures of organic solvents. 

Work practices are widely used throughout the motor vehicle manufacturing 

industry to reduce VOC emissions from cleaning operations. 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, there is insufficient information 

to correlate VOC content or vapor pressure to specific cleaning steps. 
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B. Available Controls and Regulatory Approaches 

1. Sources of VOC Emissions 

There two primary sources of VOC emissions from motor vehicle coating 

operations: evaporation of VOC from the coatings, and evaporation of VOC from 

the cleaning materials. VOC emissions depend of VOC content, transfer 

efficiency, and the presence and extent of VOC control equipment. Liquid 

coatings are reformulated to lower VOC content. VOC contents and emission 

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

Coatings 

The VOC emissions from coating application occur when solvent evaporates 

from the coating during application to the vehicle part or body. The transfer 

efficiency (ratio of the amount of coating solids deposited onto the surface of the 

object to the total amount of coating solids sprayed 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 production, thus reducing VOC 

emissions. 

Industry has steadily moved to lower VOC content coatings including powder 

coatings, waterborne coatings, and higher solids solvent-borne coatings. The 

utilization of these alternative coatings in conjunction with efficient spray 

application equipment, such as electrostatic spray, is the primary method 

currently used at motor vehicle assembly coating operations to reduce VOC 

emissions from the coatings. In addition, many facilities have also employed 

partial spray booth controls by venting spray booth emissions, principally from 

automated spray zones, through an add-on control device 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 operation of powder coatings 

because they are dry particles. Depending on the powder formulation, some 

VOC emissions may occur during the heating of the powder during curing. In 

any event, any VOC emissions from the heating of powder coatings would 

generally be much less than the VOC emissions from the heating of liquid 

coatings during the curing operations. Powder coating applications are best 

suited for long production runs of consistently sized parts without color changes. 

Powder anti-chip and primer-surfacer coatings are used at some assembly 

plants. 
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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 assembly plant uses 

waterborne electrodeposition primers. Waterborne primer-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 electrostatic and non-electrostatic 

spray techniques. 

Higher solids solvent-borne coatings contain more solids than “conventional” 

(pre-1980) solvent-borne coatings. These coatings contain less organic solvent 

VOC, per unit volume, of solids than conventional solvent-borne coatings. Thus, 

less VOC emissions escape during coating preparation, application, and curing 

to deliver a given amount of coating solids. Higher solids primer-surfacer and 

basecoat application include a combination of manual and automatic, and 

electrostatic and not-electrostatic spray techniques. 

Additional VOC emissions occur in the flash-off area after coatings are applied, 

and in baking ovens where drying and curing occur. 

Cleaning Materials 

Cleaning materials are another source of VOC emitted by motor vehicle surface 

coating operations. The VOC escape when solvents evaporate from the cleaning 

materials during use. 

Cleaning materials with low-VOC composite vapor pressure and/or low-VOC 

content generate less VOC emissions than materials with higher VOC vapor 

pressure and/or content. The VOC composite vapor pressure of a cleaning 

material is a weighted average of the vapor pressure 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 cleaning material, including 

non-VOC components such as water or exempt compounds. Water and exempt 

compounds thereby reduce the VOC composite vapor pressure of cleaning 

materials in which they are present. Although use of lower vapor pressure 

cleaning materials may reduce VOC emissions, insufficient information is 

available to correlate cleaning material vapor pressure to specific cleaning steps 

in the motor vehicle surface coating industry. Similarly, cleaning materials with 

low VOC content would generate less VOC emissions than materials with high 

VOC content; however, insufficient information is available to correlate cleaning 

material VOC content to specific cleaning steps in this industry. 
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2. Available Controls for VOC Emissions 

There are two general emission control techniques for reducing VOC emissions: 

pollution prevention measures, and emission capture and add-on control 

systems. Pollution prevention is the most prevalent control technique, followed 

by add-on control systems. Provided below is a summary of these control 

techniques. 

a. Pollution Prevention Measures 

Pollution prevention measures include product substitution/reformulation, work 

practice procedures, and equipment substitution. 

Product Substitution/Reformulation 

One pollution prevention measure is to substitute higher-solvent coatings with 

coatings containing little or no solvents. These coatings include waterborne 

coatings, higher solids coatings, and reactive coatings. Conversion to 

waterborne coatings (for example) can lower VOC emissions greatly. 

Work Practices 

Work practice procedures are physical actions intended 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, maximizing the amount of coating 

transferred to the substrate by application methods with higher transfer 

efficiencies and improved spray technique, and using 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 to 40 percent. More modern 

technologies, such electrostatic and HVLP spray equipment, achieve high 

transfer efficiencies, up to 90 percent, depending on the product shape, size, and 

substrate. The use of efficient coating application equipment reduces VOC 

emission by increasing the coating transfer efficiency. Since the 1970’s, spray 

equipment used to apply motor vehicle assembly coatings has become 

increasingly automated. 

b. Emission Capture and Add-on Control Systems 

In addition to pollution prevention measures, VOC emissions from motor vehicle 

assembly coating application operations can be reduced 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 facilities control the exhaust from 

bake ovens. Some operators have employed partial spray booth controls by 

venting spray booth emissions, principally from automated spray zones, through 

an add-on control device such as an oxidizer or hybrid (concentrator followed by 
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an oxidizer) control system. Spray booths typically 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 and alternative application 

methods are available to reduce VOC emissions. 

Capture Systems 

Capture systems collect solvent-laden air from process vents (e.g., spray booth, 

flash-off or bake oven vents) and direct the captured air to a control device. The 

majority of VOC emissions from motor vehicle assembly coating occur in the 

spray booth. The collected emissions are ducted from the spray booth directly to 

the control device. Similarly, flash-off area or bake oven exhaust is ducted 

directly to the control device. 

The design of the capture system can greatly contribute to the overall VOC 

control efficiency. An efficient capture system maximizes 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 surface coating operations: 

oxidation and hybrid systems (concentrator followed by an oxidizer). 

Oxidation 

Oxidation destroys VOC emissions in an exhaust stream by exposing the stream 

to an oxidizing atmosphere at high temperatures. Oxidizers can control bake 

oven exhaust emissions, and may be of thermal or catalytic design and combust 

VOC-container exhaust streams. Catalytic oxidizers are similar to thermal 

oxidizers but employ a catalyst to aid in the oxidation reaction. As a result, 

catalytic oxidizers operate at lower combustion temperatures relative to that 

required in thermal oxidizers. Both types of oxidizers generally utilize either 

regenerative or recuperative techniques to preheat inlet gas in order to decrease 

energy costs associated with high oxidation temperatures. 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 concentrations of VOC. 
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Hybrid Systems 

Hybrid systems consist of a concentrator followed by 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 oxidizer. 

Adsorption 

Adsorption occurs when the unbalanced molecular forces on the surface of solids 

(the adsorbant) attract and retain gases and particulate matter that encounter the 

solid. Several materials are widely used as the adsorbent, such as activated 

carbon, organic resin polymer, and inorganic materials. Each has substantial 

surface area per unit volume. 

In a typical carbon adsorber, VOC-laden air is passed through a regenerable 

fixed bed of granular activated carbon (the adsorbent). Adsorber beds are 

typically operated in parallel to avoid interruption of VOC control. In this 

arrangement, when the adsorption capacity of one bed 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 device efficiencies greater than 

95 percent. 

In contrast to combustion, carbon adsorption does not 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. Hot-air regeneration is generally 

used when dealing with water-soluble solvents. 

Carbon adsorbers are most suitable for solvents that 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 ketone. 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 subsequent purification if it 

is to be reused. The presence of solid particles or polymerizable substances in 

the inlet air stream to a carbon adsorber may require pretreatment of the inlet air. 

In addition, adsorption is usually used for exhaust streams at ambient 

temperature up to approximately 38°C (100°F). Therefore, cooling and 

dehumidification may also be required as pretreatment in some cases. 
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Work Practices 

Work practices are physical actions intended to affect emission reductions, and 

are specifically tailored to each industry. Work practices vary from a few manual 

operations to a complex program. Coating waste generated during material 

preparation, coating application, and equipment cleaning. When coating waste is 

reduced, overall VOC emissions are reduced. Coating waste may be reduced 

through work practices by effectively controlling material preparation and using 

proper equipment maintenance procedures. 

4. Available Controls for VOC Emissions from Cleaning Materials 

Pollution prevention measures from cleaning materials and activities include work 

practices, and product substitution or reformulation. Add-on control technologies 

are not in use specifically for reducing VOC emissions from cleaning operations, 

however, if cleaning operations are performed within a capture system that is 

ducted to an add-on control system, the VOC emissions from the cleaning 

operations would be reduced by the add-on control. 

a. Work Practice Procedures 

Work practice procedures reduce VOC emissions during cleaning operations by 

reducing the amount of VOC that can evaporate due to exposure to air. Work 

practice procedures include the following: 

• Cover mixing, storage, and waste vessels for VOC-containing 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 type of pollution prevention 

measures. Reducing the composite VOC vapor pressure or VOC content of 

cleaning materials used reduces VOC emissions from cleaning operations. 

However, there is insufficient information available to correlate VOC content or 

vapor pressure to specific cleaning steps. 
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IV. CURRENT AND PROPOSED REGULATIONS 

A. Current Regulations 

District Rule 4602 is currently retired, but when it was active it set limits for VOC 

emissions from the finishing and refinishing of Group I Vehicles and Group II 

Vehicles and Equipment, and from the organic solvent cleaning, and the storage 

and disposal of solvents and waste solvent materials associated with such 

finishing and refinishing. 

Existing State and Local VOC Requirements 

The following discussion is a summary of EPA actions, 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 "Control of Volatile Organic 

Emissions from Existing Stationary Sources Volume II: 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 coating 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 prime coat operation, guide coat. 

(primer-surfacer) operation and topcoat operation located in an automobile or 

light-duty truck assembly plant constructed, reconstructed, 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 1977 CTG recommendations 

for primer-surfacer and topcoat cannot be directly compared because of 

differences in the compliance period (monthly for the NSPS limits and daily for 

the CTG recommendations) and how transfer efficiency is considered. 

3. The 2004 NESHAP 

In 2004, EPA promulgated the National Emissions Standards 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 bodies or body parts; all storage 

containers and mixing vessels; and all manual and automated equipment and 

containers used for conveying coatings, thinners, cleaning materials, and waste. 

The 2004 NESHAP for automobile and light-duty truck assembly coating 
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imposed organic HAP emission limitations calculated on a monthly basis for 

existing sources, with more stringent limits for new sources. The NESHAP also 

sets emission limits for coatings not included in the CTG or 

NSPS, including glass-bonding primer, glass bonding adhesive, and some 

coatings and thinners. The 2004 NESHAP also specified work practices to 

minimize organic HAP emissions from the storage, mixing, and conveying of 

coatings, thinners, cleaning materials, and from handling waste materials 

generated by the coating operation. 

4. Existing State and Local VOC Requirements 

Fourteen States and one California air district have regulations that control VOC 

emissions from motor vehicle assembly coating. Most of the state rules have 

limits that are consistent with the 1977 CTG recommended limits. 

B. CTG Recommended Rule Requirements 

1. CTG for Automobile and Light-Duty Truck Assembly Coatings 

The CTG for Automobile and Light-Duty Truck Assembly Coatings provides 

control recommendations for reducing VOC emissions from automobile and lightduty truck assembly coating operations. In terms of applicability, EPA 

recommends the control approaches discussed in the CTG apply to facilities 

where the total actual VOC emissions from all miscellaneous industrial adhesive 

application processes, including related cleaning activities, 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 operations. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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 Proposed Amendments to Rule 4602

A. Coatings 

VOC emission limits are recommended to reduce VOC emissions from the 

coatings during the coating operations. For all the operations, except for final 

repair, the recommended limits are based on data supplied by the Alliance of 

Automobile Manufacturers member companies and non-member 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 emission limit for combined 

primer-surfacer and topcoat applications is recommended because in some 

facilities these processes are becoming indistinguishable from each other. 

Table 1. Recommended VOC Limits for Motor Vehicle Assembly Coatings 

Assembly Coating Process Recommended VOC Emission Limit 

When solids 

turnover ratio 

(RT)>0.16: 

When 

0.040<RT<0.160: 

When 

RT<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

Tkg 

VOC/liter (0.084X350

0.160-R

Tx8.34 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) less 

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 DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

16 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

Table 2 presents the recommended VOC emissions limits for miscellaneous 

materials used at motor vehicle assembly coating facilities. Limits are expressed 

as grams of VOC per liter of coating excluding water and exempt compounds, as 

applied. 

Table 2. VOC Content Limits for Miscellaneous Materials 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 apply 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 plastic parts (40 CFR Part 63, 

subpart PPPP) be used to determine the VOC content of reactive adhesives. 

EPA recommends Districts accept manufacturer’s formulation data in lieu of 

these methods. If there is a disagreement between manufacturer’s formulation 

data and the results of a subsequent test, the District should use the test method 

results unless the facility can make a demonstration to the District’s satisfaction 

that the manufacturer’s formulation data are correct. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

17 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

B. Work Practices for Coating-Related Activities and Cleaning Materials 

Work practices are recommended to reduce VOC emissions from automobile 

and light-duty truck assembly coating-related activities. Specifically, EPA 

recommends the following work practices for storage, mixing, and handling 

operations for coatings, thinners, and coating-related waste materials: 

• store all VOC-containing coatings, thinners, and coating-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, mixing, and conveying 

equipment. 

Additionally, EPA recommends that operators develop and implement a work 

practice plan to minimize VOC emissions from cleaning and from purging of 

equipment associated with all coating operations for which emission limits are 

recommended in this CTG. The plan should specify practices and procedures to 

ensure that VOC emissions from the following operations 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 facility covered by this CTG 

already has a NESHAP work practice plan in place, instead of creating other 

work practice plan to address VOC emissions, EPA recommends that he facility 

simply add to its NESHAP work practice plan procedures for minimizing non-HAP 

VOC emissions. Most elements of the NESHAP work practice 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 DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

18 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

2. CTG for Miscellaneous Metal and Plastic Parts Coatings 

The CTG for Miscellaneous Metal and Plastic Parts Coatings recommends three 

options for controlling the VOC emissions from the coatings used by 

miscellaneous metal product and plastic part surface coating facilities. In 

addition to the three options for VOC control, EPA recommends work practices. 

District Rule 4603 Surface Coating of Metal Parts and Products, Plastic Parts 

and Products, and Pleasure Crafts addresses the CTG recommendations. 

However, one section of the CTG for Miscellaneous Metal and Plastic Parts 

Coatings is addressed by District Rule 4602 Motor Vehicle Assembly Coatings. 

The portion of the CTG addressed by Rule 4602 is the 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 Miscellaneous Metal and Plastic Parts 

Coatings are identical to the VOC content limits for miscellaneous materials 

addressed by the CTG for Automobile and Light-Duty Truck Assembly Coatings. 

Glass bonding primer, adhesive, and weatherstrip adhesive coatings are not 

mentioned for heavier vehicle coatings limits in the 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 reflect 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 coating operations. 

Section 2.0 Applicability 

This section would be amended to make this rule applicable to operators who 

apply VOC-containing coatings to new automobiles, light-duty trucks, heavier 

vehicles, and other parts coated along with these bodies or body parts during 

the assembly process, and associated solvent cleaning activities. That is to say 

this rule would apply to assembly plants of new motor vehicles that have coating 

at the facility. 

Section 3.0 Definitions 

Definitions would be added and removed to reflect the new requirements and 

applicability of rule language. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

19 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

Section 4.0 Exemptions 

This section would be amended to remove previous exemptions that do not 

apply to the new rule requirements and to provide an exemption for materials 

supplied in containers with a net volume of 16 fluid ounces or less, or a net 

weight of one pound or less. 

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

actual VOC emissions from all motor vehicle assembly coating operations, 

including related cleaning activities, at that facility are less than 6.5 kg/day (15 

lb/day) before consideration of controls. This limited exemption was added to 

proposed rule language to make this rule more consistent with the CTG 

requirements. The exemption is limited because the operator must keep records 

to prove that the facility is below the threshold to be subject to VOC controls. 

Therefore, the operator will be subject to record keeping requirements of Section 

6.1. 

Section 5.0 Requirements 

This section would be amended to remove all requirements 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 automobile, light-duty truck, 

and heavier vehicle assembly coating operations. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

20 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

Section 5.1 

This section would be amended to set VOC emission limits for motor vehicle 

assembly coatings based on the assembly coating process as presented in Table 

3. 

Table 3. VOC Limit for Motor Vehicle Assembly Coating Processes 

Assembly Coating 

Process Recommended VOC Emission Limit 

When solids 

turnover ratio 

(RT)>0.16: 

When 0.040< RT

<0.160: When RT <.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 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 lb 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) less water and 

less exempt solvents on a daily weighted average basis or as 

an occurrence weighted average. 

Combined primersurfacer and topcoat 

operations 

1.44 kg of VOC/liter of deposited solids (12.0 lb 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 DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

21 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

Section 5.1 would also establish VOC emission limits, 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 Materials 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 Adhesive, and Glass Bonding 

Primer, are currently being added to the Rule 4653 (Adhesives) per the CTG for 

Miscellaneous Industrial Adhesives. These new adhesives categories would 

have different VOC limits than required by this rule. 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 that 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 limits 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 requirements for a VOC control 

system, should the operator choose to use one. The CTG does not recommend 

VOC control system requirements. However, staff recommend this rule language 

so this rule is consistent with other District prohibitory rules in allowing a VOC 

control system as a compliance option. A VOC control standard of 90% is 

consistent with Rule 4603 (Surface Coating of Metal Parts and Products), which 

would be considered the default rule for metal parts and products coatings. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

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 language that is not applicable 

to the new source category and rule requirements. This section itemizes 

standards for coating application methods that align with CTG standards and 

Rule 4603 (Surface Coating for Metal Parts and Products). 

Section 5.4 Organic Solvent Cleaning 

This section would be amended to require that solvents 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 other 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 to make this rule more 

comprehensive and to align with other District prohibitory 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 require facilities develop and 

implement a work practice plan to minimize VOC emissions from cleaning and 

from purging of equipment associated with motor vehicle assembly coating 

operations. However, if a facility is subject to the 2004 NESHAP requirements 

for a work practice plan, the operator may add to the 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 DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

23 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

Section 6.5 Test Methods 

This section would be amended to update it with correct 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 baseline 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-amending project. 

The 2007 Ozone Plan and the 2008 PM Plan make no reference to, or call for 

emission reductions from, this source category. Since the federal CAA requires 

ozone nonattainment areas to implement RACT and that 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 rules or rule amendments that 

implement Best Available Retrofit Control Technology (BARCT) or all feasible 

measure. The draft amendments to Rule 4602 would add 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 any 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 guidance, such as a federal CTG. 

Since the draft amendments to Rule 4602 implement the CTG standards 

mandated by the federal Clean Air Act, a socioeconomic impact analysis is not 

required. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4602 September 17, 2009 

24 Final Staff Report with Appendices For 

 Proposed Amendments to Rule 4602

VIII. RULE CONSISTENCY ANALYSIS 

California State Health and Safety Code, Section 40272.2, requires District staff to 

prepare a rule consistency analysis of Rule 4602 that compares the elements of 

amendments with the corresponding elements of other District rules, federal 

regulations and guidelines that apply to the same source category or type of 

equipment. Preliminary analysis has indicated that none of the draft 

requirements of this rule would conflict with federal rules, regulations, or policies 

covering similar stationary sources. District staff will prepare a rule consistency 

analysis later in the rule development process. 

IX. ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act (CEQA), District staff 

investigated the likely environmental impacts of the proposed amendments to Rule 

4602. Based on the lack of evidence to the contrary, District staff has concluded 

that the proposed amendments to the rule will not have any significant adverse 

effects on the environment. Staff recommends filing 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 Staff Report will be published 

and made available to affected sources and interested parties for their review 

and comments prior to a public hearing by the Governing Board. Comments 

received from stakeholders, ARB and EPA will be evaluated, and if appropriate, 

incorporated into the draft amendments to the rules. District staff intends to 

submit the draft rules amendments to the District Governing 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.htm

3. South Coast AQMD. “Rule 1115 Motor Vehicle Assembly Line Coating 

Operations”. May 1995. 

4. 40 CFR § 63.3176 NESHAP for Surface Coatings of Automobiles and LightDuty Trucks.