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

Febr uary, 201 12

Agency: Imperial County Air Pollution Control District ( I CAPC D)

Sip Approved Rule: Rule 427

- Automotive Refinishing Operations Adopted

– September 14 , 199 9

Submitted

– Ma y 26

, 2000 EPA Approved

– October 3

, 2001 ( 6 6 FR 50319 )

Subject of this TSD: Rule 427

- Automotive Refinishing Operations

A dopt ed

– February 23, 2010

Submitted

– July 20

, 2010

RULE SUMMARY

- I C APCD 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 f or 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” ( EPA

453/R

- 08

- 003, September 2008) and “Control Techniques Guidelines for Automobile and Light

- Duty Assembly Coatings ” (EPA

- 453/R

- 08

- 00 6

, 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 subm ittals must comply with CAA § 110(l) and § 193 regarding SIP

relaxations.3

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 t he correct date f or Method 432 is 1989, t he date for the EPA approved Method 422 is September 12, 1990 and t he 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 ACTIO N

- EPA staff recommends a full approval of Rule 427 pursuant to CAA §110(k) (4) and §301(a).

ATTACHMENT S

-

1. I CAPCD Rule 427

, Surface Automotive Refinishing Operations , as submitted on Ma y 26

, 2000

.

2. I C APCD 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

- 00 6 , 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

- 00 3 , September 200 8

. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_vo c_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf4

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.