UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Ventura County Air Pollution Control District, Rule 74.2, Architectural Coatings

Prepared by: David Grounds

Reviewed by: Andrew Steckel

February 14, 2011
RULE IDENTIFICATION

Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP Approved Rule: Rule 74.2 – Architectural Coatings

Adopted – November 13, 2001

Submitted – March 15, 2002

EPA Approved – January 2, 2004 (69 FR 34)

Subject of this TSD: Rule 74.2 – Architectural Coatings

Amended – January 12, 2010

Submitted – July 20, 2010

RULE SUMMARY – VCAPCD Rule 74.2, Architectural Coatings is a rule designed to reduce 

volatile organic compound (VOC) emissions from the coating of structures and their 

appurtenances, mobile homes, portable buildings, pavements, or curbs. Architectural coatings 

are formulated with a variety of components including pigments, resins, solvents, and different 

additives such as driers, anti-skinning agents, anti-sag agents, dispersing agents, defoaming 

agents, preservatives and fungicides. The primary source of air emissions from architectural 

coatings is the solvent component in solvent-based coatings and the co-solvents from 

waterborne coatings. Rule 74.2 is applicable to any person who supplies, sells, offers for sale, or 

manufactures, blends, or repackages any architectural coating for use within the VCAPCD, as 

well as any person who applies or solicits the application of any architectural coating within the 

VCAPCD.

The rule development is based on the Suggested Control Measure (SCM) adopted by the 

California Air Resources Board (ARB) on October 26, 2007. The SCM is a model rule which seeks 

to provide statewide consistency for the regulation of architectural coatings. The SCM was 

developed for districts that need additional emission reductions for the attainment or 

maintenance of state or federal ambient air quality standards. CARB amended the SCM to 

lower the VOC limits, improve definitions for coatings, and to promote consistency and 

uniformity among district rules. Based on population factors, VCAPCD estimates it emits 2.1 

tons per day (tpd) VOC and the estimated emission reduction from this proposed rule revision 

is about 0.5 tpd.

VCAPCD regulates a serious ozone nonattainment area for the 8-hour ozone national ambient 

air quality standard (NAAQS)(40 CFR 81), and VCAPCD designed Rule 74.2 partly to address the 

requirements for ozone non-attainment areas as described in Clean Air Act (CAA) section 182.
Changes to the SIP approved rule include:

Lowered VOC content for 19 architectural coatings.

Deleted 15 coating categories.

Added 10 new coating categories.

Deleted Averaging Provision option.

EPA EVALUATION CRITERIA -

1. Enforceability – Section 110(a)(2)(A) of the CAA requires that regulations submitted to 

EPA for incorporation into the SIP must be clear and legally enforceable.

2. Stringency -– VCAPCD regulates an ozone nonattainment area and is required to meet 

RACT (Reasonably Available Control Technology). We have compared Rule 74.2 against 

analogous rules in other areas and relevant national guidance including EPA’s Control 

Technique Guidelines (CTG) titled, “Industrial Cleaning Solvents” (EPA-453/R-06-001, 

9/06); “Control of Volatile Organic Emissions from Existing Stationary Sources, Volume I: 

Control Methods for Surface Coating Operations” (EPA-450/2-76-028, 11/76); EPA’s 

national rule for architectural coating manufacturers, “National VOC Emission Standards 

for Architectural Coatings” (40 CFR 59 Subpart D, 9/11/98); and other state and local 

rules for this category were used to help evaluate the RACT requirements of CAA §182.

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. 

EPA EVALUATON – The submitted VCAPCD Rule 74.2 is more stringent than the approved SIP, 

largely because of the lowered VOC content limits for architectural coatings. The current SIP 

submittal generally contains sufficient testing and recordkeeping requirements to satisfy 

enforcement requirements. The stringency of requirements in submitted Rule 74.2 is also 

generally consistent with relevant national guidance and analogous rules in other areas. 

RULE DEFICIENCIES - We have identified no deficiencies with Rule 74.2 sufficient for EPA to 

propose less than full approval.

RECOMMENDATIONS –

We recommend lowering the VOC content for Flat Coatings to 50 g/l to match CARB’s 

2007 SCM.

We recommend lowering the VOC content for Primers, Sealers, and Undercoaters to 

100 g/l to match CARB’s 2007 SCM.

In Section J, Definitions, we recommend adding ‘Manufacturer’s Maximum Thinning 

Recommendations’ to match CARB’s 2007 SCM.
EPA ACTION – Rule 74.2 largely fulfills the relevant CAA §110 and part D requirements. EPA 

staff recommends full approval of Rule 74.2 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES –

VCAPCD Rule 74.2, Architectural Coatings, Amended January 12, 2010.

V CAPCD Staff Report, November 10, 2009.

EPA Rule Review Comments, December 16, 2009.