UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Imperial County Air Pollution Control District, Rule 424, Architectural Coatings

Prepared by: David Grounds

Reviewed by: Andrew Steckel

January 31, 2011
RULE IDENTIFICATION

Agency: Imperial County Air Pollution Control District (ICAPCD)

SIP Approved Rule: Rule 424 – Architectural Coatings

Adopted – January 11, 2005

Submitted – April 26, 2005

EPA Approved – January 4, 2007 (72 FR 267)

Subject of this TSD: Rule 424 – Architectural Coatings

Adopted – February 23, 2010

Submitted – July 20, 2010

RULE SUMMARY – ICAPCD Rule 424, Architectural Coatings, is a rule designed to limit volatile 

organic compound (VOC) emissions during architectural coating applications. Architectural 

coatings are products that are applied to stationary structures and their accessories, and are a 

significant source of VOCs. They include house paints, stains, industrial maintenance coatings, 

traffic coatings and many other products. When these coatings are applied, VOCs are emitted 

from the coatings and solvents used for thinning and cleanup.

The rule applies to any person who supplies, sells, offers for sale, or manufactures, blends, or 

repackages any architectural coating for use within ICAPCD, as well as any person who applies 

or solicits the application of any architectural coating within ICAPCD. Rule 424 has been revised 

to match the “Suggested Control Measure for Architectural Coatings” (SCM) approved by 

California Air Resources Board (CARB) in 2007. The SCM is a model rule which seeks to provide 

statewide consistency for the regulation of architectural coatings. ICAPCD regulates a moderate 

non-attainment area for the 8-hour ozone national ambient air quality standard (NAAQS)(40 

CFR 81), and ICAPCD designed Rule 424 partly to address the requirements for ozone nonattainment areas as described in Clean Air Act (CAA) section 182.

Changes from the approved SIP rule include:

Added new severability section.

Updated standards for most restrictive VOC limits.

Expanded container labeling requirements.

Expanded reporting requirements.

Added several compliance provisions and test methods.

Added new VOC Content Limits table effective January 1, 2011.
EPA EVALUATION CRITERIA –

1. Enforceability – Section 110(a)(2)(A) of the CAA requires that regulations submitted to 

EPA for incorporation into the SIP must be clear and legally enforceable.

2. RACT (Reasonably Available Control Technology) – ICAPCD regulates an ozone 

nonattainment area. However, because Rule 424 regulates sources that are not covered 

by a CTG and that are non-major area sources, it is not subject to RACT requirements. 

While it appears RACT is not required, we have compared Rule 424 against analogous 

rules in other areas and relevant national guidance including EPA’s Control Technique 

Guidelines (CTG) titled, “Industrial Cleaning Solvents” (EPA-453/R-06-001, 9/06) and

“Control of Volatile Organic Emissions from Existing Stationary Sources, Volume I: 

Control Methods for Surface Coating Operations” (EPA-450/2-76-028, 11/76); EPA’s 

national rule for architectural coating manufacturers, “National VOC Emission Standards 

for Architectural Coatings” (40 CFR 59 Subpart D, 9/11/98); and other state and local 

rules for this category.

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

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

EPA EVALUATION - – The submitted ICAPCD Rule 424 is more stringent than the approved SIP, 

largely because of the lowered VOC content limits for architectural coatings and increased 

records reporting details. The current SIP submittal generally contains sufficient testing and 

recordkeeping requirements to satisfy enforcement requirements. The stringency of 

requirements in submitted Rule 424 is also generally consistent with relevant national guidance 

and analogous rules in other areas. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 424 sufficient for EPA to 

propose less than full approval.

RECOMMENDATIONS – The following revisions are not currently the basis for rule disapproval, 

but are recommended for the next time the rule is amended.

We recommend removing Section D.6, Rust Preventive Coatings, since CARB’s 2007 SCM 

does not include this section.

We recommend removing Section D.8, Lacquers, since CARB’s 2007 SCM does not 

include this section.

We recommend removing Section E.6, Clear Brushing Lacquers, since CARB’s 2007 SCM 

does not include this section.
We recommend removing Section E.9, Quick Dry Enamels, since CARB’s 2007 SCM does 

not include this section.

We recommend removing Section G.5.f, Drying Times, since CARB’s 2007 SCM does not 

include this section.

We recommend removing Section G.5.g, Surface Chalkiness, since CARB’s 2007 SCM 

does not include this section.

Correct one remaining typographical error in section G.5.i, “Parachlorobenzotribluoride” 

should be corrected to “Parachlorobenzotrifluoride.”

EPA ACTION – Rule 424 largely fulfills the relevant CAA §110 and part D requirements. EPA staff 

recommends full approval of Rule 424 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES –

ICAPCD, Rule 424, “Architectural Coatings,” Adopted February 23, 2010.

ICAPCD, Rule 424, “Architectural Coatings,” Adopted January 11, 2005.

CARB’s “Suggested Control Measures for Architectural Coatings”, 2007.

ICAPCD, Staff Report.

EPA’s Comment Letter, February 18, 2010.

ICAPCD response to EPA Comment Letter, February 22, 2010.

ICAPCD Rule 101, Definitions, Amended February 23, 2010.