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 427, Automotive Refinishing Operations 

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

February, 2011
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Agency: Imperial County Air Pollution Control District

(ICAPCD)

Sip Approved Rule: Rule 427 - Automotive Refinishing Operations 

Adopted – September 14, 1999

Submitted– May 26, 2000

EPA Approved – October 3, 2001 (66 FR 50319)

Subject of this TSD: Rule 427 - Automotive Refinishing Operations 

Adopted – February 23, 2010

Submitted –July 20, 2010 

RULE SUMMARY - ICAPCD Rule 427, Automotive Refinishing Operations, is a 

rule designed to limit volatile organic compound (VOC) emissions from facilities 

engaged in coating operations of motor vehicles and mobile equipment. It also 

limits VOC emissions from organic solvent cleaning and storage and disposal of 

solvents and waste solvent materials associated with such coating. The rule 

describes related recordkeeping, reporting, and monitoring requirements and test 

methods for determining various VOC content and emissions. In general, the 

rule was changed to adopt the CARB Suggested Control Measure (SCM) for 

Automotive Coatings as approved by the Board on October 20, 2005. 

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), the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 

Plans, General Preamble for the Implementation of Title I of the Clean Air 

Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help 

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

enforceability. 

2. RACT – EPA’s Control Technique Guidelines (CTGs) titled, “Control 

Techniques Guidelines for Miscellaneous Metal and Plastic Parts” (EPA453/R-08-003, September 2008) and “Control Techniques Guidelines for 

Automobile and Light-Duty Assembly Coatings” (EPA-453/R-08-006, 

September 2008), and California’s Suggested Control Measure (SCM) titled 

“Suggested Control Measure for Automotive Coatings” as approved by the 

board on October 20, 2005 and other state and local rules for this category 

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

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.
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The monitoring, recordkeeping, reporting and other requirements generally ensure 

that Rule 427 can be enforced. 

We believe the 2008 CTGs generally help define RACT for this activity. Rule 427 

implements RACT because it is more stringent than the 2008 CTGs.

The new submittal generally strengthens the previous SIP submittal and complies

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

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

The following revisions regarding test methods are not currently the basis for rule 

disapproval, but are recommended for the next time the rule is amended:

a. The EPA approved version of test method 1613 listed in Section E.2 

is 1996.

b. In general, all EPA test methods listed in Section E.5 should include 

complete titles.

c. Please note that SCAQMD test method 318-95 listed in Section E.7

must be validated for any metal other than aluminium.

d. In Section E.8 the correct date for Method 432 is 1989, the date for 

the EPA approved Method 422 is September 12, 1990 and the date 

for the EPA approved SCAQMD Method 303-91 is August, 1996.

e. The SCAQMD method entitled in Section E.9 is Method TE. 

EPA ACTION - EPA staff recommends a full approval of Rule 427 pursuant to 

CAA §110(k) (4) and §301(a). 

ATTACHMENTS -

1. ICAPCD Rule 427, Surface Automotive Refinishing Operations, as 

submitted on May 26, 2000.

2. ICAPCD Rule 427, Surface Automotive Refinishing Operations, as 

submitted on July 20, 2010. 

ADDITIONAL REFERENCES -

1. “Control Techniques Guidelines for Automobile and Light-Duty Truck 

Assembly,” EPA-453/R-08-006, September 2008.

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

006_auto_ldtruck_assembly_coating.pdf

2. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts

Coatings,” EPA-453/R-07-003, September 2008.

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

003_misc_metal_plasticparts_coating.pdf
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2. “Automotive Coatings Suggested Control Measure”, as approved by the 

Board on October 20,2005

http://www.arb.ca.gov/coatings/autorefin/scm/sreport/appenda.pdf

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

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

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

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