UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

f or EPA ’ s Proposed Rulemaking

f or 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

Febr uary

, 20 1 12

RULE IDENTIFICATION

-

Agency: San Joaquin Valley Air Pollution Control District (S JV APCD )

SIP Approved Rule: Rule 460 2

– 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 460 2

– Motor Vehicle Assembly Coatings

A dopt ed

– September 17, 2009

Submitted

– May 17, 2010

RULE SUMMARY

- SJV APCD Rule 460 2

, 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 vario us 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 s tringent 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, Augu st 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

- 00 6 , September 2008 )

, Control Techniques Guidelines for

Misc ellaneous 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)

.3

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 Ligh t

- 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 co mplies 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. R ule 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 regulate s motor vehicle assembly coating operations, and, as such, approval of this version of the rule creates heretofore

undefined SIP requirements for mo tor 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 4 6 02 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:4 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 consi stency, 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 titl e 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 t est 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. P lease 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 t han 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

t he 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 fo r storing, mixing and conveying coating materials.5

EPA ACTION

- The rule largely fulfils the relevant CAA §110 and CAA part D requirements. EPA staff recommends full approval of Rule 460 2 pursuant to CAA § 110(k) (3) and § 301(a).

ATTACHMENTS

- 1. SJV APCD Rule 460 2

, Motor Vehicle Assembly Coatings , as submitted on May 17, 2010

. 2. SJVAPCD Rule 460 2

, 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

- 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_voc_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf

3. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, a nd 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.