UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Direct Final Rulemaking

For the

California State Implementation Plan

Northern Sierra Air Quality Management District, Rule 228, 

Surface Coating of Metal Parts and Products

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

December, 2011
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Agency: Northern Sierra Air Quality Management District 

(NSAQMD)

Superseded Submittals: Adopted – November 27, 2006

Submitted – March 7, 2008

Amended - February 22, 2010

Submitted - July 20, 2010 

Subject of this TSD: Rule 228 - Surface Coating of Metal Parts and 

Products

Amended – April 25, 2011

Submitted – September 27, 2011

RULE SUMMARY - NSAQMD Rule 228, Surface Coating of Metal Parts and 

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

from the application of coatings, surface preparation materials, and cleanup 

materials in metal parts and products coating operations. As stated in Section 1.1, it 

applies to portions of the Northern Sierra Air Quality Management District 

(NSAQMD) that are designated as non-attainment for federal ambient air quality 

standards for ozone per 40 CFR 81.305. Exemptions in Section 1.2 include total 

coating use that does not exceed the 2.7 tons per rolling 12-month period, touchup and repair coatings with the exception of VOC limits and work practices, 

coatings for which other rules exist, coatings whose usage does not exceed the 55 

gallon per rolling 12-month period limit and strippers used for cured coatings. VOC 

limits for the applicable coating materials are indicated in Section 3.1 and alternate 

limits with add-on controls are listed in Section 3.2. Work practices are outlined in 

Section 3.4 and 3.5, recordkeeping requirements are stipulated in Section 4.2 and 

test methods are listed in Section 5.0. 

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 evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability
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2. Stringency – EPA’s Control Technique Guidelines (CTG) titled, “Control 

Techniques for Miscellaneous Metal and Plastic Parts Coatings” (EPA453/R-08-003, September 2008) and other state and local rules for this 

category, including SCAQMD’s Rule 1107, Coating of Metal Parts and 

Products, were used to help evaluate the RACT requirements of CAA 

§182(c)(1). 

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

with attainment or other provisions of the Act.

Enforceability - The testing, recordkeeping, monitoring and other rule requirements 

generally ensure that the submitted rule can be enforced. 

Stringency – Rule 228 is generally as stringent as the relevant CTGs and analogous 

rules in other nonattainment areas that we have approved as RACT (73 FR 

70883). The 2011 staff report states that this rule has no effect on emissions.

Rule Relaxation - 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.

EPA ACTION - EPA staff recommends a full approval of Rule 228 pursuant to 

CAA §110(k) (4) and §301(a). 

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. Section 1.1 stipulates that this rule only regulates those portions of the 

District that are in nonattainment for any federal ambient air quality 

standard for ozone. We suggest that this rule regulate all sources of VOCs 

in metal coating operations in the District in accordance with CAA §182(b) 

(2) (C), for equity in the District and to obtain additional VOC emission 

reductions that may help the nonattainment areas. If the District requires 

separate rules for attainment and nonattainment areas, refer to 40 CFR 

81, section 305 to specify which regions are regulated by this rule.
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2. Please consider removing Section 1.2.6 and establishing VOC content 

limits for strippers such as contained in SCAQMD Rule 1107, Section (c) 

(3).

3. The air dried VOC limits for Prefab Architectural Multi-Component and 

Prefab Architectural One-Component categories listed in Section 3.1 are

consistent with the CTG values. However, SCAQMD’s rule 1107 has lower 

values for these categories, effective 7-01-2007. Please consider adopting 

these lower limits.

4. The capture efficiency and control efficiency minimum of 90% required in 

Section 3.2.2 seems to be consistent with the overall efficiency of 90% 

suggested by the CTG. However, please consider clarifying the criteria in 

Section 3.2.2 to, “In lieu of complying with VOC content limits specified in 

Subsection 3.1 or the emission rate limitation in 3.2.1, air pollution control 

equipment with an overall efficiency of 90% may be used ...” Overall 

efficiency is defined as the product of capture efficiency and control 

efficiency.

5. The work practices in Section 3.4 basically exempts the application of the 

work practices at facilities using control equipment as defined in Section 

3.2.2. The CTG recommends that the work practices be applied to all

control options, including that which includes add-on controls affording a 

90% overall efficiency. We suggest applying the work practices for solvent 

cleaning to those facilities that opt for the add-on control methods defined 

in Section 3.2.2. 

6. Please consider the following minor changes: 

a. Change “does” to “do” in Section 1.2.1: “...VOC emissions (excluding 

exempt compounds) from all coatings does not exceed 2.7 tons...”

b. For consistency, add definitions in Section 2.0 for Airless Spray and 

Air-assisted Airless Spray which are listed in Section 3.3.

c. For clarity, provide the correct titles of ASTM E169 which is entitled 

“Standard Practices for General Techniques of Infrared Quantities 

Analysis”. 

EPA ACTION - EPA staff recommends a full approval of Rule 228 pursuant to 

CAA §110(k) (4) and §301(a). 

ADDITIONAL REFERENCES –

1. NSAQMD Rule 228, Surface Coating of Metal Parts and Products, as 

submitted on April 25, 2011.
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2. NSAQMD Rule 228, Surface Coating of Metal Parts and Products, as 

adopted on November 27, 2006. 

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

4. “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

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

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

http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf