UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

San Joaquin Valley Air Pollution Control District, 

Rule 4602, Motor Vehicle Assembly Coatings

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

February, 2011
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RULE IDENTIFICATION -

Agency: San Joaquin Valley Air Pollution Control District

(SJVAPCD)

SIP Approved Rule: Rule 4602 – Motor Vehicle and Mobile Equipment 

Coating Operations

Adopted –December 20, 2001

Submitted- February 20, 2002

EPA Approved – June 26, 2002 (67 FR 42999)

Retired locally - January 1, 2009

Subject of this TSD: Rule 4602 – Motor Vehicle Assembly Coatings 

Adopted – September 17, 2009

Submitted – May 17, 2010

RULE SUMMARY - SJVAPCD Rule 4602, Motor Vehicle Assembly Coatings is a 

rule amended to limit volatile organic compound (VOC) emissions from Motor 

Vehicle Assembly Coating operations. 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. The original Rule 4602, Motor 

Vehicle and Mobile Equipment Coating Operations, was retired on January 1, 

2009 when Rule 4612, Motor Vehicle and Mobile Coating Operations – Phase II, 

became effective, imposing generally more stringent controls for the sources 

previously addressed by the original Rule 4602.

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 Guideline (CTG) titled “Control 

Techniques Guidelines for Automobile and Light-Duty Assembly Coatings”

(EPA-453/R-08-006, September 2008), Control Techniques Guidelines for 

Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003, 

September, 2008) and other state and local rules for this category were 

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

We believe that, in general, Rule 4602 is adequately clear and enforceable 

consistent with CAA §110(a)(2)(A). 

Rule 4602 closely resembles Control Techniques Guidelines for Automobile and 

Light-Duty Truck Assembly Coatings (EPA-453/R-08-006) which we believe is a 

reliable source for satisfying RACT. The 6.5 kg/day VOC emission limit is lower 

than the CTG’s 6.8 kg/day limit.

Rule 4602 was also amended to implement the control options and work practices

for motor vehicle coatings, as recommended in Control Techniques Guidelines for 

Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003).

For comparable coating categories Rule 4602 is generally more stringent than the 

only two district rules for automobile assembly coating: BAAQMD Rule 8-13 (12-

25-95) and amended SCAQMD Rule 1115 (5-12-95). 

Rule 4602 was amended to require that solvents used for solvent cleaning have a 

VOC content equal or less than 25 g/l, which makes this standard as stringent as 

other prohibitory rules of the District.

For these reasons, we believe Rule 4602 implements RACT and complies with 

CAA §182(b) (2).

Requirements for Motor Vehicle and Mobile Equipment Coating Operations, 

previously contained in Rule 4602, are now described in Rule 4612. Rule 4612 

was fully approved by the EPA (75 FR 2796) on 12-15-09 with no additional 

recommendations for the next rule version. According to the District’s RACT 

Demonstration, dated April 2009, Rule 4612 incorporates all of the elements of 

the California Air Resources Board’s (ARB’s) Suggested Control Measures (SCM) 

for this source category. Rule 4602 now regulates motor vehicle assembly coating 

operations, and, as such, approval of this version of the rule creates heretofore 

undefined SIP requirements for motor vehicle assembly coating and does not 

relax the SIP in violation of CAA §110(l) and §193. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 4602

sufficient for EPA to propose less than full approval. 

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. Please consider making the following formatting and editorial changes:
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a. For consistency with the standard definition of HVLP, please include 

“measured dynamically at the center of the air cup and at the air 

horns,” after “...air atomizing pressure” in Section 3.4.0.

b. Please clarify the definition of Motor Vehicle Assembly Coating 

Operation in Section 3.46 to state that this is a process of applying 

rather than a person who applies. 

c. For clarity, please change the word “and” before electrodeposition to 

“an”.

d. For consistency, refer to Rule 4663 for Solvent Flushing, as was 

done for the definition of Solvent.

2. Please make the following changes for clarity and consistency with the 

Little Bluebook:

a. In Sections 6.5.1 and 6.5.7, the ARB methods should have the 

complete title and date of the EPA-approved version. 

b. The EPA method in Section 6.5.2 should have the complete title of 

the NESHAP, National Emission Standards for Surface Coating of 

Plastic Parts and Products, April 19, 2004.

c. The date of the EPA-approved version of test method ASTM D1613, 

referenced in Section 6.5.4 is 1996.

d. The designator of the two SCAQMD methods referred to in Sections 

6.5.5 and 6.5.6 are TE and CS respectively. Please note that, 

according to ARB, neither of these can be used for emission results. 

e. Please change the date of the guideline in Section 6.5.7.1 to 1994.

3. In Section 5.3.7, the 2008 CTG requires that any other application have as 

good transfer efficiency as the HVLP application method. The criteria 

should state this requirement rather than the 65 percent transfer efficiency.

4. In Section 6.1, for the weighted averaging indicated in Table 1 of Section 

5.0, please be more specific in how recordkeeping is done for both a daily 

weighted and occurrence weighted averaging basis. See, e.g., page 11 of 

the Little Bluebook. 

5. The Work Practices in Section 6.3 only includes regulations about cleaning 

solvents. The 2008 CTG recommends work practices for coating-related 

activities and cleaning materials. Please provide work practices for storing, 

mixing and conveying coating materials.
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EPA ACTION - The rule largely fulfils the relevant CAA §110 and CAA part D 

requirements. EPA staff recommends full approval of Rule 4602 pursuant to CAA 

§110(k) (3) and §301(a). 

ATTACHMENTS -

1. SJVAPCD Rule 4602, Motor Vehicle Assembly Coatings, as submitted on

May 17, 2010.

2. SJVAPCD Rule 4602, Motor Vehicle and Mobile Equipment Coating 

Operations, as submitted on February 20, 2002.

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

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

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

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

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