UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Rulemaking

for the

California State Implementation Plan

Yolo

- Solano Air Qualit y Management District Rule 2.26

Motor Vehicle and Mobile Equipment Coating Operations

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

October 20151

RULE IDENTIFICATION

- Agency Yolo

- Solano Air Quality Management District (YSAQMD)

.

SIP Approved

Rule Rule 2.26

- Motor Vehicle and Mobile Equipment Coating

Operations (MVMECO)

. A dopted

- April 27, 1994

. Submitted

- February 24, 1995

. EPA Approved

- April 30, 1996 ( 61 FR 18962 )

.

Subject of this

TSD Rule 2.26

- MVMECO

.

Amended

- December 10, 2008

. Submitted

- June 26, 2015

.

Completeness

Finding Determination of Completeness letter : August 13, 2015.

BACKGROUND

- Yolo

- Solano Air Quality Management District (YSAQMD) is

classified for the federal 8

- hour 2008 Ozone Standard as Severe Nonattainment. 1

As a result, YSAQMD is required by Clean Air Act (CAA) §182( b) (2) to implement

reasonab ly available control technology (RACT) for any sources subject to an

EPA Control Techniques Guidelines (CTG) or for major sources (>25 tons per

year ) of VOC

. We have reviewed the California Air Resources Board (CARB)

Emission Inventory Facilities Database and identify no major sources of VOC

subject to Rule 2.26 , and EPA does not have a CT G for automotive coating

refinishing. Therefore YSAQMD is not obligated to implement RACT for the

category of MVMECO

.

According to the Final Staff Report associated with Rule 2.26

, “ The District is

revising the rule to incorporate the CARB Suggested Control Measure for

Automotive Coatings (SCM). District Staff is also proposing to incorporate

other minor changes resulting in improvement to rule clarity, effectiveness, and

consistency with other agencies. 2

The main revisions to Rule 2.26 will include the following:

1. Group I and Group II categories will be combined. The same Volatile

Organic Compound (VOC) limits will apply for passenger vehicles, heavy

- duty vehicles, and mobile equipment,

2. The composite VOC limit for multi

- stage systems will be eliminated and

1 40 CFR Ch. I §81.305

2 YSAQMD Final Staff Report, “ Proposed Amendments to Rule 2.26, Vehicle and Mobile

Equipment Coating Operations ,” November 26, 2008 .p3.2 replaced with specific VOC limits for clear coatings and color coatings,

3. Coating categories will be simplified,

4. The exemption for touch

- up coatings will be removed,

5. Sunset provisions will be created for current requirements which will not

apply when the new limits take effect,

6. A prohibition of possession provision will be added, and

7. Recordkeeping and labeling requirements will be modified for

consistency with other Districts and improved enforcement. ”

RULE SUMMARY

- YSAQMD Rule 2.26, establishes VOC content limits and

workplace standards for MVMECO

. It also describes related recordkeeping,

reporting , and monitoring requirements. The December 10, 2008 version has

been revised to conform to the California Air Resources Board (C ARB)

“Suggested Control Measure (SCM) for Automotive Coatings as Approved by the

Board on October 20, 2005. ” Rule 2.26 was not submitted until 2015 but was

a dopted by the YSAQMD on December 10, 2008

. A ll “sunset provisions” have

expired since July 1, 2009

.

EVALUATION CRITERIA

- 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) req uirement for enforceability.

2. Stringency

- The Code of Federal Regulations (CFR) Title 40 Subpart B

National Volatile Organic Compound Emission Standards for Automobile

Refinish Coatings §59.102 Standards table 1 (40 CFR 59.102, table 1), the

SCM proposed by CARB for Automotive Coatings and other state and local

rules for this category were used to help evaluate the RACT requirements of

CAA § 182(b) and § 182( d ) , although RACT is not required of this rule at this

time

.

3. SIP Relaxation

- CAA § 11 0(l) prohibits EPA from approving any SIP revision

that would interfere with any applicable requirement concerning attainment

and reasonable further progress (RFP) or any other applicable requirement

of the CAA. In addition, CAA § 193 prohibits the modifica tion of any SIP

-3 approved control requirement in effect before November 15, 1990, in a

nonattainment area.

In applying these criteria to the submitted rule, we referred to the following

guidance and policy documents:

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

(the "Blue Book"), US EPA, OAQPS (May 25, 1988).

2. Guidance Document for Correcting Common VOC and Other Rule

Deficiencies , EPA Region IX (August 21, 2001, the “Little Bluebook”).

3. State Implementation Plans; General Pr eamble for the Implementation of

Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16,

1992); 57 FR 18070 (April 28, 1992).

4. Final Rule To Implement the 8

- Hour Ozone NAAQS

– Phase 2 , 70 FR

71612 ( Nov. 25, 2005).

EPA EVALUATION

-

1. The rule requirements and applicability are clear, and the monitoring,

recordkeeping, reporting and other provisions sufficient ly ensure that

affected sources and regulators can evaluate and determine compliance

with Rule 2.26 consistently.

2. The submitte d rule conforms to the requirements of CARB’s SCM and t he

VOC limits are significantly more stringent than the National Volatile Organic

Compound Emission Standards for Automotive Refinish Coatings

(NVOCESARC , 40 CFR 59, subpart B ). Among the District rule s in

California that have implemented the SCM and have been approved into the

State Implementation Plan (SIP) are:

a. South Coast Air Quality Management District ( SCAQMD ) Rule 1151

, Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating

Operations.

b. San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD)

Rule 4612, MVMECO

.

c. Ventura County Air Pollution Control District (VCAPCD) Rule 74.18

MVMECO

.

YSAQMD Rule 2.26 is similar to these other rules and implements RACT

level requirement s.

3. We propose to determine that our approval of the submittal would comply

with CAA §§ 110(l) and 193 because (1) the proposed SIP revision would

not interfere with the on

- going process for ensuring that requirements for

RFP and attainment of the NAAQS are met, and (2) the emission limits in4 the submitted rule are more stringent than the exi sting SIP

- approved control

requirements that they would replace.

RULE DEFICIENCIES

– We find no deficiencies with Rule 2.26 to preclude a full

approval of Rule 2.26.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The

following revi sion is not currently the basis for rule disapproval, but is

recommended for th e next time the rule is amended:

Consistent with National Emission Standards for Hazardous Air Pollutants, Paint

Stripping and Miscellaneous Surface Coat ing Operations , (40 CFR

§63.11173(e)(1)

, Subpart HHHHHH) ) we recommend adding a requirement that

all painters must be trained and certified after training.

EPA ACTION

-

The submitted Rule 2.26 strengthens the SIP

. The rule fulfils the relevant CAA

§110 and part D requirements. Therefore, EPA staff recommends approval of

Rule 2.26 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES

1. YSAQMD Rule 2.26

- Motor Vehicle and Mobile Equipment Coating

Operations approv ed into the SIP on April 30, 1996 (61 FR 18962 ).

2. YSAQMD Rule 2.26

- Motor Vehicle and Mobile Equipment Coating

Operations Rule 2.26 amended December 10, 2008 and s ubmitted to the

EPA on June 26, 2015

. 3. http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

. 4

. YSAQMD Final Staff Report, “ Proposed Amendments to Rule 2.26, Vehicle

and Mobile Equipment Coating Operations,” November 26, 2008

. 5

. CARB Resolution 05

- 46, October 20. 2005, Attachment A, “Suggested

Control Measure for Automotive Coatings. ”

6

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

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

, 1988

. ( http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf ).

7

. “Guidance Document for Correcting Common VOC & Other Rule

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

( http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf ).

8

. National Volatile Organic Compound Emission Standards, 40 CFR §

59.102, Subpart B, Table 1,VOC Content Limits for Automobile Refinish

Coatings.

9

. SCAQMD District Rule 1151, amended December 2, 2005 and approved

into the SIP on September 24, 2013 (78 FR 53773)

.5

10

. SJVAPCD District Rule 4612, amended October 21, 2010, and approved

into the SIP on February 13, 2012 (77 FR 7536)

. 11

. VCAPCD Rule 74.18, amended November 11, 2008, and approved into the

SIP on September 24, 2013 (78 FR 58459)

. 12

. National Emission Standards for Hazardous Air Pollutants, Paint Stripping

and Miscellaneous Surface Coating Operations (40 CFR §63.11173(e)(1)

(Subpart HHHHHH) )

.