UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1151, 

Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations

Prepared by: Nicole Law and Adrianne Borgia

Reviewed by: Andrew Steckel

October 2012
-2-

Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule: Rule 1151 – Motor Vehicle and Mobile Equipment NonAssembly Line Coating Operations

Adopted – December 11, 1998

Submitted – February 16, 1999

EPA Approval - May 26, 2000 (65 FR 34101)

Prior Proposed Action: Rule 1151 – Motor Vehicle and Mobile Equipment NonAssembly Line Coating Operations 

Amended – December 2, 2005 

Submitted – April 6, 2009

EPA Limited Approval-Limited Disapproval – December 

29, 2009 (74 FR 68759)

Subject of this TSD: Rule 1151 – Motor Vehicle and Mobile Equipment NonAssembly Line Coating Operations 

Amended – December 2, 2005

Submitted – April 6, 2009

RULE SUMMARY - Rule 1151 establishes VOC content limits and workplace 

standards for motor vehicle and mobile equipment coating operations. It also 

describes related recordkeeping, reporting, and monitoring requirements. Changes 

from the approved SIP rule include:

1. Purpose and applicability sections have been edited to remove Group I and 

II classifications. 

2. Added and removed definitions to clarify rule language.

3. Added language to exempt tertiary butyl acetate (TBAc) as a VOC.

4. Removed distinctions between Group I and II coatings in the requirements 

section. There is now only one table displaying VOC limits, which have 

been lowered and updated to match limits in CARB’s SCM.
-3-

5. The category of specialty coatings was removed as was the provision on 

using specialty coatings.

6. Added subsections on the prohibition of possession of noncompliant coatings

and administrative requirements for manufacturers.

7. Removed the exemption on touch-up and stencil coatings. 

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule: 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Rule Stringency – EPA’s Control Technique Guidelines (CTG) for, “Reduction 

for Volatile Organic Compound Emissions from Automobile Refinishing” (EPA450/3-88-009), dated October 1988, CARB’s Suggested Control Measure 

(SCM) titled, “Suggested Control Measure for Automotive Coatings,” (approved 

by the board on October, 2005) and other state and local rules for this 

category were used to help evaluate the rule stringency. 

3. Relaxation - Where previous versions of rules have been SIP approved, new 

submittals must comply with CAA §110(l) and §193 regarding SIP relaxations.

Enforceability - The monitoring, recordkeeping, reporting and other requirements 

generally ensure that the submitted rule can be enforced. 

Stringency - Since SCAQMD is an extreme nonattainment area for ozone, the 

district must implement RACT requirements pursuant to CAA section 182(b)(2). We 

believe Rule 1151 fulfills RACT requirements because the VOC limits are generally 

more stringent than the CTG for, “Reduction for Volatile Organic Compound 
-4-

Emissions from Automobile Refinishing” and are equivalent to the limits set forth in 

CARB’s SCM for Automotive Coatings.

We note that TBAc is defined as an exempt VOC in subsection G.16. Although the 

recordkeeping/reporting of TBAc remains a requirement pursuant to 40 CFR Part 

51.100 (s)(5), EPA does not consider the lack of recordkeeping/reporting an 

obstacle to approving the rule because the recordkeeping provision is to determine if 

usage of t-butyl acetate is significantly increasing as a result of its exemption as 

opposed to being used to determine a facility's compliance with the rule's specific 

VOC limits. Further, the State will continue to have a recordkeeping/reporting 

obligation for TBAc unless and until EPA completes a rulemaking to revoke the 

requirement in 40 CFR 51.100(s), which we have been petitioned to do.

SIP Relaxation - In addition, we believe the submitted rule is more stringent than the 

version previously approved into the SIP, so the submitted rule does not relax the 

SIP and complies with CAA §110(l) and §193.

EPA’s PREVIOUS PROPOSED ACTION -

On December 29, 2009(see 69 FR 69298), we proposed a limited approvallimited disapproval of this rule because we determined that while it largely fulfilled 

the relevant CAA requirements regarding RACT, enforceability and rule relaxations, 

one rule deficiency was identified - the exclusion of recordkeeping or reporting for 

TBAc, as required by 40 CFR 51.100(s)(5).

However, we no longer believe that omitting the requirement for recordkeeping, 

emissions reporting, photochemical dispersion modeling and inventory requirements 

on the exempt compound TBAc is sufficient basis to disapprove this rule. As 

discussed in the previous section, “...TBAc will not be VOC for purposes of VOC 

emissions limitations or VOC content requirements.”1, which are the basis for 

 

1. 40 CFR 51.100(s)(5)
-5-

compliance with this rule by a facility. In addition, the State will continue to assume 

the responsibility for the reporting, modeling and inventory requirements.

In response to this prior proposed limited disapproval action, Lyondell Chemical 

Company commented that they encouraged the EPA to reconsider the limited 

disapproval of this rule because the TBAc reporting and recordkeeping requirements 

“are burdensome, arbitrary, contrary to the goals of the Clean Air Act (CAA), and 

should be rescinded.” 2Lyondell, as the developer and producer of TBAc, also 

indicated that it has and continues to provide TBAc sales data to the EPA and that 

other reported emissions data would be inaccurate. The arguments were convincing 

enough to engage EPA in a discussion of the merits of this provision and to reverse 

our proposed decision on this rule. 40 CFR 51.100(s)(5), to date, remains 

unchanged but we no longer consider it an adequate justification for disapproval of 

SCAQMD Rule 1151. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended. 

1. To stay consistent with requirements in CARB’s SCM, consider revising 

subsection (d)(4)(A) to state the required efficiency of an emission control 

system shall be calculated by an equation and achieve an overall control 

efficiency of 85 percent or greater.

2. In subsection (d)(7), several references are incorrect. In (A)(iii), revise 

(h)(1)(E) to (h)(1)(F) and revise (d)(6)(A)(ii) to (d)(7)(A)(ii). In (B), 

revise (d)(6)(A) to (d)(7)(A).

3. In subsection (e)(3)(B) delete “or does not meet” to be consistent with the 

format in (e)(2)(B) and to accurately include the VOC limits and meeting the 

 

2. January 27, 2010 letter Re: Comments on the California State Implementation Plan, South Coast 

Air Quality Management District and Ventura County Pollution Control District (EPA-R09-OAR-2009-

0754, sent by Dan Pourreau, Project Manager of Lyondell Chemical Company to EPA. 
-6-

requirements for exempt compounds and carcinogenic materials as provisions 

to sell or offer for sale or distribute coatings.

4. In subsection (f)(2), the recordkeeping of key system parameters which need 

to ensure or document compliance should refer to subsection (d)(4)(A), 

Alternative Compliance, Emission Control System, instead of (d)(3)(A) which 

does not exist. 

EPA ACTION -

The submitted Rule 1151 fulfills the relevant CAA §110 and part D requirements. 

Therefore, EPA staff recommends a full approval of Rule 1151 pursuant to CAA 

§110(k) (3) and §301(a). This analysis and recommendation replaces the TSD 

prepared in support of our 12/29/09 proposed action (74 FR 68759). 

ATTACHMENTS -

1. SCAQMD Rule 1151, Motor Vehicle and Mobile Equipment Non-Assembly 

Line Coating Operations, as submitted on April 6, 2009.

2. SCAQMD Rule 1151, Motor Vehicle and Mobile Equipment Non-Assembly 

Line Coating Operations, as submitted on February 16, 1999.

3. CARB Suggested Control Measure (SCM) for “Automotive Coatings” as 

approved by the Board on October 20, 2005.

ADDITIONAL REFERENCES -

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (cover only).

2. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001

(cover only).

3. 69 FR 69298, November 29, 2004, Revision to Definition of Volatile Organic 

Compounds – Exclusion of t-Butyl Acetate 
-7-

4. EPA’s Control Technique Guidelines (CTG), “Control Technique Guidelines 

for Emissions from Automobile Refinishing” (EPA-450/3-88-009), October 

1988. 

5. Alternative Control Techniques (ACT) Document, “Automotive Refinishing” 

(EPA-453/R-94-031), April 2004.