UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Direct Final Rulemaking

For the

California State Implementation Plan

Placer County Air Pollution Control District, Rule 245, Surface Coating of Metal 

Parts and Products

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

November 2010
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RULE IDENTIFICATION 

Agency: Placer County Air Pollution Control District (PCAPCD)

Superseded Submittals: Amended – December 11, 2008; 

Submitted – September 18, 2009

Subject of this TSD: Rule 245- Surface Coating of Metal Parts and 

Products

Amended – August 20, 2009; 

Submitted – January 10, 2010

RULE SUMMARY – PCAPCD Rule 245, Surface Coating of Metal Parts and 

Products, is a rule designed to limit volatile organic compound (VOC) emission

from the application of coatings, coating removers (strippers), surface 

preparation materials, and cleanup materials in metal parts and products coating 

operations. VOC limits for applicable coating materials are indicated in Table 1 of 

Section 301. Recordkeeping is stipulated in Section 501 and test methods are 

outlined in Section 503.

EVALUATION CRITERIA - The following criteria and guidance documents 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. RACT – EPA’s Control Technique Guidelines (CTG) titled, “Control 

Techniques for Miscellaneous Metal and Plastic Parts Coatings” (EPA453/R-08-003) and other state and local rules for this category were used to 

help evaluate the RACT requirements of CAA §182(b)(2). 

3. Rule Relaxation – CAA §110(l) and §193 restrict SIP revisions that interfere 

with attainment or other provisions of the Act.

EPA EVALUATION

The monitoring, recordkeeping, reporting and other requirements generally ensure 

that the submitted rule can be enforced. 

We believe Rule 245 implements RACT partly because it is generally as stringent 

as the 2008 CTG which has been issued for this activity with regard to coating of 

metal parts. We note, however, that the 2008 CTG also addresses coating of 

plastic parts, which is not addressed by Rule 245. As part of a broader 

demonstration of RACT, PCAPCD will need to adopt additional requirements for 

plastic parts equivalent to the CTG, or submit a negative declaration 
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demonstrating that implementation of the CTG would not affect any plastic part 

coating operations in PCAPCD.

Since no previous version of these requirements is already in the SIP, approval of 

this version only improves the SIP and does not relax the SIP in violation of CAA 

section 110(l) or 193.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 245

sufficient for EPA to propose less than full approval. 

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. Please revise the introductory paragraph for section 105 to read, “Except 

for recordkeeping and work practices requirements...” As a result of this 

change, please revise Section 501.1.2 to “Classification according to 

terminology used in Sections 105, 301, 302 and 303.” 

2. Please consider the following changes to definitions: 

a. After initial use of “Volatile organic components” in Section 101, add 

“(VOC).”

b. Revise sections 220, 226, 227, 232, 233, 248, 253, 257 and 264 

consistent with the definitions in the 2008 CTG, SCAQMD Rule 

1107 or SMAQMD Rule 451.

c. Revise title of Section 242 to “Military Specification Coating. 

d. Delete any material or term from the definitions list that is not 

referenced in this rule. For example, Aluminum Coating for Window 

Frames and Door Frames and Non-skid Coating are not included in 

301.

3. Please consider using the lower values for air-dried Prefabricated 

Architectural Coating per SCAQMD’s Rule 1107 in Section 301. 

4. Sections 302.1 and 302.7 should be revised to require the appropriate 

application methods indicated in the 2008 CTG:

a. For example in Section 302.1, “Electrostatic attraction” should be 

“Electrostatic Application” and “Roll Coat” should be “Roll Coater”.

b. Section 503.5 should be revised to agree with the coating type 

listed in Section 301: “Metallic and Iridescent Coating”.

5. Several references have not been updated to reflect previous section 

changes:

a. Section 402.4 references Section 270. This should be changed to 

Section 272. 
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b. Sections 405, 501.3, 501.3.1, 501.3.2, 503.3 and 503.4 reference 

Section 304. This should be changed to Section 305. 

c. Section 503.2 references Section 224. This should be changed to 

Section 225.

d. Section 501.3.2 also references Section 235. This should be 

changed to Section 236.

6. Please revise Section 403 to be consistent with the 2008 CTG (page 28) 

to require that all VOC–containing materials, including thinners and any 

other additives, be included when determining the coating unit’s emission 

rate. See, for example, SMAQMD Rule 451, Section 403. 

7. Please revise Section 501.1.3 to list all mixing ratios and delete the phrase 

“, if different from the manufacturer's recommendation.” This change will 

eliminate the need for Section 501.1.4.

8. In Section 503.5, please use the correct methods listed in SCAQMD Rule 

1107: Method 311-91, “Analysis of Percent Metals in Metal Coatings by 

Spectrographic Method” and SCAQMD's Method 318-95, “Determination of 

Weight Percent Elemental Metal in Coatings by X-Ray Diffraction”.

9. Similar to SCAQMD Rule 1107, please consider revising Section 503.6 to 

read, “The acid content of pretreatment wash primers and etching filler

shall be measured...”

10. We note that Rule 245 does not address plastic parts coating operations 

while the 2008 CTG does. PCAPCD will need to adopt additional 

requirements for plastic parts equivalent to the CTG, or submit a negative 

declaration demonstrating that implementation of the CTG would not affect 

any plastic part coating operations in PCAPCD.

EPA ACTION -

The District staff report states that Rule 245 was amended to address the 2008 

CTG and we have found this to be the case. EPA staff recommends approval of 

Rule 245 pursuant to CAA §110(k) (3) and §301(a). 

ATTACHMENTS -

1. PCAPCD Rule 245, Surface Coating of Metal Parts and Products, as 

submitted on August 20, 2009

ADDITIONAL REFERENCES -

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

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

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

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.
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3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts 

Coating,” EPA-453/R-08-003, September 2008.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-

003_misc_metal_plasticparts_coating.pdf