### SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

FINAL STAFF REPORT

Proposed Amended Rule 1151

- Motor Vehicle And Mobile Equipment Non

- Assembly Line Coating Operations

September 2014

Deputy Executive Officer, Planning, Rul e Development, and Area Sources Elaine Chang, Dr.PH

Assistant Deputy Executive Officer, Planning, Rul e Development, and Area Sources Philip M. Fine, Ph.D.

Planning and Rules Manager, Planning, Rul e Development, and Area Sources Naveen Berry

AUTHOR : Don Hopps AQ Specialist REVIEWED BY : David Ono Program Supervisor Karin Manwaring Senior Deputy District Counsel

CONTRIBUTORS : Barbara Radlein AQ Specialist/CEQA Shah Dabirian AQ Specialist/SocioeconomicsSOUTH COAST AIR QUALITY MANAGEMENT D ISTRICT GOVERNING BOARD

CHAIRMAN: DR. WILLIAM A. BURKE Speaker of the Assembly Appointee
VICE CHAIRMAN: DENNIS YATES Mayor, Chino Cities of San Bernardino MEMBERS: MICHAEL D. ANTONOVIC H Supervisor, Fifth District County of Los Angeles

BEN BENOIT Mayor Pro Tem, Wildomar Cities of Riverside County

JOHN J. BENOIT Supervisor, Fourth District County of Riverside

JOE BUSCAINO Councilmember, Fifteenth District City of Los Angeles

MICHAEL A. CACCIOTTI Councilmember, South Pasadena Cities of Los Angeles County/Eastern Region

JOSIE GONZALES Supervisor, Fifth District County of San Bernardino

JOSEPH K. LYOU, PH. D. Governor’s Appointee

JUDITH MITCHELL Mayor, Rolling Hills Estates Cities of Los Angeles County/Western Region

SHAWN NELSON Supervisor, Fourth District County of Orange

DR. CLARK E. PARKER, SR. Senate Rules Appointee

MIGUEL A. PULIDO Mayor, Santa Ana Cities of Orange County

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN , D. ENV.TABLE OF CONTENTS

EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

................................ ................................ ................................ ................................ ..................... ES

- 1

CHAPTER 1

– BACKGROUND ON PROPOS ED AMENDED RULE 1151

INTRODUCTION

................................ ................................ ................................ ................................ ................................ ....... 1

- 1

REGULATORY HISTORY

................................ ................................ ................................ ................................ ....................... 1

- 1

AFFECTED FACILITIES

................................ ................................ ................................ ................................ .......................... 1

- 1

PROCESS DESCRIPTION

................................ ................................ ................................ ................................ ........................ 1

- 2

SPRAY GUN TECHNOLOGY AND TRANSFER EFFICIENCY

................................ ................................ .................... 1

- 3

CHAPTER 2: SUMMARY O F PROPOSED AMENDED R ULE 1151

OVERVIEW: PROPOSED AMENDMENTS TO RULE 1151

................................ ................................ ........................... 2

- 1

REMOVE OBSOLETE RULE LANGUAGE

................................ ................................ ................................ ........................ 2

- 1

SUBDIVISION (A) PURPOSE

................................ ................................ ................................ ................................ .................. 2

- 1

SUBDIVISION (B ) APPLICABILITY

................................ ................................ ................................ ................................ .... 2

- 2

SUBDIVISION (C) DEFINITIONS

................................ ................................ ................................ ................................ .......... 2

- 2

SUBDIVISION (D) REQUIREMENTS

................................ ................................ ................................ ................................ ... 2

- 7

SUBDIVISION (E) PROHIBITION OF SALES, SPECIFICATION AND SALE

................................ ......................... 2

- 10

SUBDIVISION (F) RECORDKEEPING REQUIREMENTS

................................ ................................ ........................... 2

- 13

SUBDIVISION (G) ADMINISTRATIVE REQUIREMENTS

................................ ................................ .......................... 2

- 14

SUBDIVISION (H) TEST METHODS

................................ ................................ ................................ ................................ .. 2

- 1 5

SUBDIVISION (I) RULE 442 APPLICABILITY

................................ ................................ ................................ ................ 2

- 1 7

SUBDIVISION (J) EXEMPTIONS

................................ ................................ ................................ ................................ ........ 2

- 17

CHAPTER 3 : IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1151

E

MISSION I MPACT A SSESSMENT

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C OST A NALYSIS

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I NCREMENTAL C OST

- E

FFECTIVENESS

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C

ALIFORNIA E NVIRONMENTAL Q UALITY A CT (CEQA)

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S OCIOECONOMIC I MPACT A SSESSMENT

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D RAFT F INDINGS UNDER C ALIFORNIA H EALTH AND S AFETY C ODE 40727

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C OMPARATIVE A NALYSIS

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- 2

D RAFT C ONCLUSIONS AND R ECOMMENDATIONS

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P

UBLIC C OMMENTS AND R ESPONSES

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REFERENCES

................................ ................................ ................................ ........................... R

- 1

LIST OF TABLES

T

ABLE 1

- P ERMIT F ACILITIES A ND P ERCENTAGE D ISTRIBUTION

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- 2

T

ABLE 2

– T ABLE OF S TANDARDS

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iRULE 1151

– MOTOR VEHICLE AND MOBILE EQUIPMENT NON

- ASSEMBLY LINE
COATING OPERATIONS

EXECUTIVE SUMMARYExecutive Summary Final Staff Report

EXECUTIVE SUMMARY
Rule 1151

- Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations

- is a source specific rule that was adopted to reduce Volatile Organic Compound (VOC) emissions

, toxic air contaminant s , stratospheric ozone

- depleting compound s , and global

- warming compound emissions from automotive coating operations performed on motor vehicles, mobile equipment and associated parts or components for motor vehicle s and mobile equipment.

The prior amendment to the rule was on December 2, 2005

, w hich effectively split Rule 1151 into two parts with two subsequent effective dates for compliance. The first part of Rule 1151, the original rule, became effective on December 2, 2005

, and remained in effect through June 30, 2008. The second part of Rul e 1151, identified as Appendix A to the rule, became effective on July 1, 2008

, superseding and making obsolete the first part of the rule. The two part structure of Rule 1151 currently contains 18 pages of obsolete language immediately followed by 16 pag es of currently effective rule language, Appendix A. This structure continues to cause confusion to the regulated community.

T he proposed amendment seeks to make administrative changes to the rule to enhance the understanding of current applicable rule r equirements by removing obsolete rule language and making minor revisions and editorial corrections. The proposed amendment also adds new definitions to promote clarity and consistency, and further aligns the transfer efficiency equivalency section with the state Suggested Control Measure (SCM)

. This staff proposal is
administrative in nature and will not affect the current VOC limits or existing work practices . It
is not expected to yield additional VOC reductions or increases

. No socioeconomic impact s are anticipated from this proposal.

Proposed Amended Rule 1151 ES

- 1 September 2014RULE 1151

– MOTOR VEHICLE AND MOBILE EQUIPMENT NON

- ASSEMBLY LINE
COATING OPERATIONS

CHAPTER 1: BACKGROUND ON PROPOSED AMENDED RULE 1151

ο INTRODUCTION

ο REGULATORY HISTORY

ο AFFECTED FACILITIES

ο PROCESS DESCRIPTION

ο SPRAY GUN TECHNOLOGY AND TRANSFER EFFICIENCY REQUIREMENTSChapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

INTRODUCTION
Rule 1151

- Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations

- is a source specific rule that was adopted to reduce Volatile Organic Compound (VOC) emissions, toxic air contaminants, stratospheric ozone

- depleting compounds, and global

- warming compound emissions from automotive coating operations performed on motor vehicles, mobile equipment and associated parts or components for motor vehicles and mobile equipment.

REGULATORY HISTORY
Rule 1151 was adopted on Ju l y 8 , 19 88

, and has been subsequently amended twelve times. The
most recent amendment was on December 2 , 200 5

, which incorporated portions of the 2003 AQMP Control Measure CTS

- 10 and portions of the state S uggested Control Measure (SCM)

. The amendment included reductions in VOC limits for certain coating categories, a prohibition of possession, an exemption for Tertiary Butyl Acetate (TBAc) as a VOC for formulated coatings, excep t for color and clear coatings, and modified certain categ ories such as combining Group I and Group II vehicles

, combining all primer subcategories into a general primer
category
, and eliminat ing the s p ecial t y coating category. The 2005 amendment revised Rule 1151 into a two part rule based on effective date s

. The first part of Rule 1151 was effective from

D ecember 2

, 2005

, through June 30, 2008. The second part of Rule 1151, identified as “Appendix A” to the rule, bec a me effective on July 1, 2008, thus superseding the first part of
Rule 1151. The two part structure of Rule 1151 currently contains 18 pages of obsolete language immediately followed by 16 pages of current ly effective rule language, Appendix A . This structure continues to cause confusion to the regulated community

.

AFFECTED INDUSTRIES
Rule 11 51 is applicable to any person who supplies, sells, offers for sale, manufactures, or distributes any automotive coating or associated solvent for use within the District, as well as any person who uses, applies, or solicits the use or application of any a utomotive coating or
associated solvent within the District. To determine how many facilities are affected by Rule 1151, s taff researched the C L ean Clean Air Support System ( Class ) database using Standard Industrial Classification code (SIC) 7532

- Top, Body, and Upholstery Repair Shops and Paint Shops a s the search criteria . The CLASS database contains 1,079 Rule 1151 facilities. This
database identif ies required air permits which are typically for paint spray booths. Table 1

- Permit And Percentage Distribution shows the distribution of these facilities i n the four county

areas. At a recent meeting with the California Autobody Association (CAA) , representatives reported to staff that there are approximately 7,000 active body shops in Cali fornia, statewide

, with approximately 3,150 of those facilities in the southern California area , as estimated based on population

. Staff believes the difference between the SCAQMD identified number of
facilities and CCA’s estimation reflects the presence of facilities that conduct auto body repair
work but without a paint spray booth and facilities that may not be exclusively conduct ing auto

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body and paint operations such as car dealerships, fleet operators , and truck body builders , that
do not fall under SIC code 7532

.

TABLE 1

– FACILITIES AND PERCENTAGE DISTRIBUTION

COUNTY ACTIVE FACILITIE S ( CLASS ) PERCENTAGE

Los Angeles County 700 65% Orange County 196 18% Riverside County 83 8% San Bernardino County 100 9%

AQMD Jurisdiction 1,079 100%

PROCESS DESCRIPTION Rule 1151 is applicable to all automotive and mobile equipment (such as trains, railcars and truck trailers) refinishing operations that are not a part of a motor vehicle assembly line coating operation. Rule 1151 should not be confused with Rule 11 1 5

- Motor Vehicle Assembly Line Coating Operations which is applicable to all assembly line coating operations conducted during the manufacturing of new motor vehicles [ with the exception of facilities subject instead to Rule
1132

– Further Control Of VOC Emissions From High

- Emitting Spray Booth Facilities

, which applies to larger operations, e

. g. Toyota Auto Body California ( T A B C) ]

.

Automotive refinishing products are used during the repair process to address damage during manufacture, transit o r during the service life of the vehicle , and are also used in the restoration, color change and customization of the vehicle as well. Automotive coatings are used in automotive refinishing operations to form a film that serves to beautify, preserve, repa ir or protect the surface of a motor vehicle, mobile equipment or associated parts and components. Automotive refinishing can be grouped into five broad categories: auto body repair/paint shops, production auto body paint shops, new car dealer repair/pain t shops, fleet operators repair/paint shops, and truck body

- builders.

Automotive refinishing is typically performed on vehicles that have sustained exterior body damage by conditions such as road hazards or collision. Many damaged vehicles are repaired b y a process known as spot repair or for larger afflicted areas, panel repair. Spot repairs can be as small as a door ding and panel repairs are typically larger areas that may require a complete panel replacement , such as a front fender or a door. Less common refinishing operations may include a complete repainting of the entire vehicle, to either renew weather ed paint

, complete a color change , an automotive restoration, or vehicle customization

. The process for the repair

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work for a d amaged vehicle would include the physical repair of the damaged area, such as dent removal, application of body fillers, conditioning of substrate for subsequent coatings, and the application of an undercoat followed by the topcoat(s).

Automotive refini shing coatings are typically grouped into two different classes, undercoats and topcoats. Undercoats primarily prepare the substrate for subsequent coat ing s. Undercoats include adhesion promoters for plastic parts, pretreatment coatings for bare metal su rface etching, and primers, primer sealers, primer surfacers, and weld

- through primers which are used

to undercoat the surface prior to application of the topcoat (s) . Top coats are typically applied onto prepared primed surfaces and include single

- stage c oatings, color and clear coat coating
systems, and multi

- color coatings . Uniform finish coatings are used for blending a spot repair into the surrounding areas for proper color match. Other coating types include underbody coatings which are used on the under s ide of the exterior body s uch as inner fender

- well and chassis paint which is typically used on floor boards and frame rails. B ed liner coatings are used to coat the bed of pick

- up trucks but have also been used as underbody coatings due to their
hi gher resistance to damage

.

After a motor vehicle, mobile equipment or associated parts and components have been
refinished

, the coating will need to cure. Non

- assembly line coating operations may use several methods to achieve curing including air dry, forced air dry, infrared heat lamps or a forced air heater. The assembly line coating operations use ovens that thermally cure the coating, a method that cannot be accomplished by non

- assembly line coating operat i o n s due to the damage the heat
would cause to plastic parts such as headlights, tail lights, instrument panels and gauges, cloth or leather interior materials, and rubber parts such as weather

- stripping and tires.

When the repainted motor vehicle, mobile equipment or associated parts and components have fully cured, the final stage in automotive refinishing entails detail ed sanding of the new finish (in some cases), polishing the finish and reassembly of any components that were removed from the
vehicle to facilitate access to the body wor k . The vehicle is then cleaned , waxed and detailed in preparation for the final presentation for the customer.

SPRAY GUN TECHNOLOGY AND TRANSFER EFFICIENCY REQUIREMENTS Spray guns are the preferred application equipment used by the automoti v e coatings industry to apply automotive coatings

. The typical spray gun is a pistol shaped device that employs a trigger
lever to release the compressed air source to atomize the a u tomotive coating into a sprayable material. The spray gun typically comes in two dif ferent coating feed systems . T he gravity feed, where a paint cup is fixed on top of the spray gun allow s the coating to feed down via gravity to the gun body where the coating is then atomized with supplied compressed air. The second type of spray gun is the siphon feed, or suction feed, where the paint cup is fixed below the gun body
and

, when ready to spray, the compressed air source is forced through the gun body and creates a

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venturi effect thus drawing the paint from the paint cup. The spray gun has relatively few working parts : a trigger lever, which activates the spray gun for spray painting ; a fluid needle, which restricts the flow of the coating through the spray gun ; a fluid orif i ce, where the coating is expelled from the spray gun to atmosphere ; and

, an air cap, which typically has two air horns,
one on each side of the fluid orif i ce, thus allowing compressed air to directly impact the coating material stream expelled from the fluid or i f i ce to form the desired fan spray pattern. The mixing
of t he compressed air and coating is known as atomization. Paint spray guns have been in use since the early 1920s to spray finishes on a multitude of substrates including automobiles. High Volume, Low Pressure spray equipment or HVLP came to the forefront i n regu l ated areas due to its ability to transfer more atomized coating onto the substrate th a n what went to atmos p here.

W hen comparing convention al spray technology to HVLP technology

, when using a the conventional spray gun

, results in approximately one third of the atomized coating goes onto the
substrate and two thirds goes to atmosphere. When spraying with a HVLP technology, two
thirds of the atomized coating goes onto the sub s trate and one third of the atomized coating goes to atmosphere. The substr ate that is spray coated is also a factor as a large flat surface will absorb more of a sprayed coating compared to a wrought iron gate which consist s of multiple
round bars with open space between the bars

. Overspray is the sprayed coating that does not
land on the substrate but rather becomes entrained in the air where the solvents readily evaporate and add to the already polluted air of southern California.

Prior to 1924, automobiles were hand painted by using a brush to apply shellacs and varnishes. The shellacs and varnishes were time consuming to apply and it was difficult to completely
brush out all the brush marks before the finish dried. Nitrocellulose lacquer was later introduced
for automotive fi nishes however, the nitrocellulose lacquer also dried too quickly for hand applications. A new application process was introduced, air atomized spray guns, which could spray the nitrocellulose coatings on a vehicle about 10 times faster than hand applicat ion and it produce d a higher quality finish. Today there are several technologies for spray application and they are discussed below.

Conventional Conventional spray guns are high pressure, high volume technology and are still manufactured by industry an d are sold in areas where strict air pollution rules have not been implemented. This spray gun technology will not meet the transfer efficiency requirements for SCAQMD and are not compliant for use to spray automotive coatings under the purview of SCAQMD Rule
1151.

Electrostatic Spray Application Electrostatic spray application is another method of coating application where an electrostatic attraction is created between the part to be coated and the paint particles. This process is similar to powder coating and requires specialized application equipment. The electrostatic application

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is facilitated by inducting an electric charge into the liquid paint prior to spraying the paint onto a grounded object using a spray g un specific to electrostati c application. The high transfer efficiency of this system, up to 98% claimed by some manufacturers, is accomplished by the attraction of paint particles to the surface of the grounded object. Manufacturers claim that the charg ed paint particles can actually change direction in mid air, even up to 180 degrees, before attracting to a grounded object. A typical use T ypical use s for electrostatic application are new replace ment automotive body panels such as replacement fenders, ho ods, truck lids and patch panels.

High Volume Low Pressure (HVLP) HVLP spray guns are the staple of spray guns and were created to meet the transfer efficiency requirements of governmental agencies

, including the SCAQMD. HVLP spray guns can meet
the high transfer efficiency requirement and operate at less than 10 psi at the air cap . HVLP

spray guns are used in the South Coast Air Basin to spray coatings for a multitude of categories including automotive coatings, metal coatings, wood coatings, industrial coatings and marine coatings.

Low Volume Low Pressure (LVLP) LVLP spray guns are a subset of non

- conventional spray guns and may be used in the spraying of automotive coatings provided they m e et the transfer efficiency requirements as stipulated identifie d in Rule 1151 clause (d)(6)(A)(iv) or clause (d)(6)(A)(v) . LVLP offers an alternative to HVLP because they have less air flow requirements and can be used with a smaller compressor. This makes LVLP appealing for mobile painters and applicators that use a small air compressor. Manufacturers of LVLP spray guns state that LVLP can operate at less than 10 psi at the air cap and achieve transfer efficienc ies equival ent to HVLP application

. The working speed of LVLP is not as fast as HVLP spray guns.

Low Volume Medium Pressure (LVMP) LVMP spray guns are a subset of the non

- conventional spray guns and may be used in the spraying of automotive coatings provided the requirements in Rule 1151 clause (d)(6)(A)(v) for transfer efficiency are met including achieving equivalent or better transfer efficiency to HVLP

us ing the test method protocols prescribed in Rule 1151 to determine transfer efficiency, and obtaining written approval from the Executive Officer prior to use.

Reduced Pressure (RP) RP spray guns are a subset of non

- conventional spray guns and may be used in the spraying of automotive coatings provided the requirements in Rule 1151 clause (d)(6)(A)(v) f or transfer efficiency are met including achieving equivalent or better transfer efficiency to HVLP us ing the test method protocols prescribed in Rule 1151 to determine transfer efficiency, and obtaining written approval from the Executive Officer prior to use. RP spray guns also use smaller air

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compressors because they need less air flow requirements than HVLP spray guns which makes RP attractive for mobile painters. RP can be an alternative to HVLP and has a fast working speed comparable to HVLP guns

.

Pressure Fed (PF) PF spray guns are unique as compared to the other types of spray guns in that they are equipped with auxiliary containers used for holding larger quantities of coating product. PF spray guns can be used in the spraying of automotive coat ings provided all the requirements in Rule 1151
clause (d)(6)(A)(v) for transfer efficiency are met including achieving equivalent or better transfer efficiency to HVLP us ing the test method protocols prescribed in Rule 1151 to
determine transfer efficienc y, and obtaining written approval from the Executive Officer prior to

use

.

New Conventional (NC)
Staff has identified an additional subset of conventional spray guns being marketed as New
Conventional (NC) which appear s to be new technology . M anufacturer s of such spray guns claim the NC spray guns offer the same wide pattern (spray) as the old conventional spray guns but have better transfer efficiency

, and have the ability to spray thick fluids. This technology could be used for spraying automotive coatings but only if the spray gun meets all the requirements in Rule 1151 clause (d)(6)(A)(v) for transfer efficiency including achieving equivalent or better transfer efficiency to HVLP us ing the test method protocols prescribed in Rule 1151 to determine transfer efficiency, and obtaining written approval from the Executive Officer prior to use

.

Transfer Efficiency Requirements Rule 1151 has transfer efficiency requirements for a pplying an automotive coating to non

assembly line coating operation s to a motor vehicle, mobile equipment, or their associated parts and components. The transfer efficiency require ment for spray application is use of electrostatic, HVLP spray equipment

, and other spray guns that meet the HVLP definition of definition of paragraph (c)( 17 ) in design and use. Demonst r ation must be based on the manufacturer’s published technical material on the design of the spray gun and by demonstration of the operation o f the spray gun using an air pressure tip gauge from the manufacturer of the spray gun [ See clause (d)(6)(A)( i v) ]

.

Brush and roller coating are applied directly from the paint brush bristles or the roller to the substrate and have a very high coating to s ubstrate transfer efficiency. Dip coatings are simply a container filled with paint where an object is dipped into the coating which also provides a very high coating to substrate transfer efficiency. Brush, roller and dip coating processes are proposed to be included as compliant transfer efficiency processes as specified in clause

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(d)(6)(A)(iii) of the transfer efficiency requirements in order to be to be consistent with the Coating Application Methods provision in the state Suggested Control Measure.

I n addition, Rule 1151 provides for two test methods for spray guns that do not meet the HVLP definition in design and use to determine if such spray gun s can meet the transfer efficiency requirements, SCAQMD method “Spray Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989” and SCAQMD “Guidelines for Demonstrating Equivalency With District Approved Transfer Efficiency Spray Gun September 26, 2002” [See clause (h)(1)(F)] . Any spray gun used in the SCAQMD jurisdiction must meet the criteria for these test methods to qualify as a compliant transfer efficient spray gun for use in the SCAQMD jurisdiction.

Automotive Graphic Arts Operations and Brush, Roller, Dip Automotive Graphic Arts Operations include artistic design s such scenic murals, custom lettering, and other custom paint effects such as tablecloth lace designs, scallops, flames, and
multi

- hued designs typically used on customized vehicles. Pinstriping is a custom paint technique that can be used to separate different color s or to just add custom pin

- thin design graphics to a vehicle. These paint tricks are performed with a multitude of application methods such as modified paint brushes, specialized dagger style brushes specific to pinstriping

, and various types of roller a pplications . I n some cases, custom painters may even use a sponge to
achieve a desired effect. Dip coatings are simply a container filled with paint that an object is dipped into to receive its coating. Automotive graphic arts operations are proposed to be exempt under paragraph (j)(4) from the transfer efficiency requirements in order to be consistent with the Coating Application Methods provision in the state S uggested Control Measure

.

Truck Bed Liner and Underbody Coatings Truck bed liner and underbody coatings are thicker viscosity coatings that may require specialized application equipment for application. Truck bed liner coatings are typically rubberized coating s that are sprayed into the truck bed cavity to protect the cavity o f pick

- up trucks from scrapes and scratches when hauling cargo. Underbody coatings are typically

“ rubberized asphaltic ” coating s and are used for sound deadening or corrosion protection and are
typ ically applied to areas such as wheel wells, the inside of door panels or fenders, the underside
of a truck or hood or the underside of the vehicle itself

. Truck bed liner and underbody coatings

are also being proposed to be exempt under paragraph (j)(4) from the transfer efficiency requirements in order to be to be consistent with the Coating Application M ethods provision in
the state Suggested Control Measure

.

Proposed Amended Rule 1151 1

- 7 September 2014RULE 1151

– MOTOR VEHICLE AND MOBILE EQUIPMENT NON

- ASSEMBLY LINE
COATING OPERATIONS

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1151

ο OVERVIEW: PROPOSED AMENDMENT TO RULE 1151

ο REMOVE OBSOLETE RULE LANGUAGE

ο SUBDIVISION (A) PURPOSE

ο SUBDIVISION (B) APPLICABILITY

ο SUBDIVISION (C) DEFINITIONS

ο SUBDIVISION (D) REQUIREMENTS

ο SUBDIVISION (E) PROHIBITIONOF SALES, SPECIFICATION AND SALE

ο SUBDIVISION ( F) RECORDKEEPING REQUIREMENTS

ο SUBDIVISION (G) ADMINISTRATIVE REQUIREMENTS

ο SUBDIVISION (H) TEST METHODS

ο SUBDIVISION (I) RULE 442 APPLICABILITY

ο SUBDIVISION (J) EXEMPTIONSChapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

OVERVIEW: PROPOSED AMENDMENT TO RULE 1151 Proposed Amended Rule (PAR) 1151

– Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations is a source specific rule that regulates the automotive coating industry through limiting various automotive coating categories with prescribed VOC content limits and through the implementation of work practices

. In an effort to enhance the understanding of current applicable rule requirements, the proposed amendment seeks to make administrative changes to the rule by removing obsolete rule language

, and by making minor revisions and editorial corrections. The proposed amendment also adds new definitions to promote clarity and consistency

, and further aligns the transfer efficiency equivalency requirements with the state Suggested Control Measure (SC M)

. This staff proposal is administrative in nature and will not affect the current VOC limits or work practices impacted by the rule.

The December 2, 2005 amendment effectively split Rule 1151 into two parts with two subsequent effective dates for compl iance. The first part of Rule 1151, the original rule, became effective on December 2, 2005 and remained in effect through June 30, 2008. The second part of Rule 1151, identified as Appendix A, became effective on July 1, 2008 and superseded the first part of the rule , which is now obsolete.

REMOVE OBSOLETE RULE LANGUAGE Staff recognizes that the two part structure of the existing rule is rather cumbersome and has often been confusing to the regulated community. The current version of Rule 1151 requires familiarity with the rule structure in general and requires diligence in reading since the first part of the rule is comprised of 18 pages of obsolete rule language immediately followed by 16 more pages of Appendix A

, which is the operative p ortion of the rule . The current format may result in the reader referring to the VOC content limits in the first part of the rule instead of the more stringent VOC content limits in Appendix A . T his could result in potential compliance issues
with select ion of appropriate coatings. Staff is proposing to delete the obsolete portion of Rule 1151 and retain the currently applicable Appendix A language

. Additionally, staff intends to make minor revisions to the purpose

, applicability, rule definitions, tabl e of standards formatting

, requirements

, and other subdivisions of the current rule language and include clarifications and editorial corrections as necessary. The proposed rule amendment is outlined below

, identified by
rule subdivision.

SUBDIVISION (A) PURPOSE
Staff is propos ing to make minor revisions to this paragraph to improve the clarity of the purpose
of the rule and by adding the additional text “ associated parts and components. ”

“ The purpose of this rule is to limit reduce volatile organic compound (VOC) emissions, toxic air contaminants, stratospheric ozone

- depleting compound s , and global

- warming compound emissions from automotive coating s operations associated with the coating of applications

onto motor vehicles

, and mobil e equipment , and associated parts and components .”

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SUBDIVISION (B) APPLICABILITY
Staff is propos ing to make minor revisions to this paragraph to improve clarity

.

“ This rule is applicable to any person who supplies, sells, offers for sale, markets, manufactures, blends, packages, repackages, possesses or distributes any automotive coating
or associated solvent or associated solvent for use within the District, as well as any person who uses, applies, or solicits

, the use or application of any automotive coating or associated
solvent within the District

. ”

SUBDIVISION (C) DEFINITIONS Subdivision (c) contains the definitions to Rule 1151 and th is proposed amendment includes three types of revisions : three new defin itions are being proposed to be added to promote clarity and consistency ; edits and corrections are being proposed to certain existing definitions to improve clarity ; and

, three unnecessary definitions are being proposed for delet ion

.

Proposed new definitions to be added to Rule 1151 The following new definitions are proposed to address automotive graphic arts operations

, make

a reference to Rule 1171

– Solvent Cleaning Operations to be consistent with other SCAQMD

rules and to address stakehold er inquiries related to appropriate categorization of weld

- through primers as a defined primer.

“(7) AUTOMOTIVE GRAPHIC A RTS OPERATION means the application of logos, letters, designs, numbers, or graphics to a painted surface by brush, roller or airbrush .”

“(2 5 ) SOLVENT CLEANING OPE RATIONS is as defined in rule 1171

– Solvent Cleaning Operations .”

“(3 3 ) WELD

- THROUGH PRIMER means an automotive coating designed and labeled exclusively to provide a bridging or conducting effect for corrosion protection following welding .”

Proposed revisions to existing Definitions The proposed amendment adds new definitions to promote clarity and consistency. Revisions are proposed for a number of existing definitions:

(1) ADHESION PROMOTER means a any automotive coating, which is specifically labeled and formulated to be applied to uncoated plastic surfaces to facilitate bonding of subsequent automotive coatings, and on which, a subsequent automotive coating is applied

.

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(2) AEROSOL COATING PRODUCT means a pressurized coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand

- held application , or for use in specialized equipment for ground traffic/marking applications

.

(4) ASSOCIATED PARTS AND COMPONENTS means structures, devices, pieces, modules, sections, assemblies, subassemblies, or elements of any motor vehicle s or mobile equipment that are designed to be a part of any motor vehicle s or mobile equipment but which are not attached to any motor vehicle s or mobile equipment at the time of the application of an automotive coating to such the structure, device, piece, module, section, assembly, subassembly, or element. The Associated parts and
components definition does do not include circuit boards

.

(5) AUTOMOTIVE COATING means any coating or coating component used or recommended for use in motor vehicle s , or mobile equipment or associated parts and components in refinishing, service, maintenance, repair, restoration, or modification, except metal plating activities. Any reference to automotive refinishing or automotive coating made by a per son on the container or in product literature constitutes a recommendation for use in motor vehicle

, or mobile equipment and associated parts and components refinishing

.

(6) AUTOMOTIVE COATING C OMPONENT means any portion of a coating, including, but not limited to, a reducer or thinner, toner, hardener, and additive, which is
recommended by any person to distributors or end

- users for use in an automotive coating, or which is used in an automotive coating. The raw materials used to produce the components are not considered automotive coating components

.

(10) (9) CLEAR COATING means any automotive coating that contains no pigments is formulated with materials that do not impart color and is specifically labeled and formulated for application over a color coating or clear coating

.

(12) (11) COLOR COATING means any pigmented automotive coating, excluding automotive adhesion promoters, primers, and multi

- color coatings, that requires a subsequent
clear coating and which is applied over primer

, or adhesion promoter or color coating

. Color coatings include metallic/iridescent color coatings

.

(13) (12) ELECTROSTATIC SPRAY APPLICATION means any method of spray application of

automotive coatings where an electrostatic attraction is created between the part to be coated and the paint particles

.

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The proposed amended language for definitions # 14 1 5 and # 15 16 are shown below in part, less equation s language . T here are no changes to either equation.

(16) (1 5 ) GRAMS OF VOC PER LIT ER OF COATING LESS W ATER AND LESS EXEMPT COMPOUNDS, OR REGULATORY VOC, is the weight of voc per combined volume of voc and coating solids and shall be calculated by the following equation :

(17) (1 6 ) GRAMS OF VOC PER LIT ER OF MATERIAL, O R ACTUAL VOC

, is the weight of
VOC per volume of material and shall be calculated by the following equation :

The following revisions are proposed for the remainder of the existing definitions:

(18) (17) HIGH

- VOLUME, LOW

- PRESSURE (HVLP) means spray application equipment designed to atomize 100 percent by air pressure only and is operated between 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing pressure measured dynamically at the center of the air cap and at the air horns.

(19) (1 8 ) METALLIC/IRIDESCENT COLOR COATING means any automotive coating that contains more than 0.042 pounds per gallon (5 grams per liter) of metal or iridescent particles as applied, where such particles are visible in the dried film

.

(21) (20) MOTOR VEHICLE means any self

- propelled vehicle, including, but not limited to, motorcycles, passenger cars, light

- duty trucks and vans, medium

- duty and heavy duty vehicles as defined in Section 1900, Title 13, of the California Administrative Code. Additional examples include, but are not limited to, b uses, golf carts, vans, motorcycles, tanks, and armored personnel carriers

.

( 22) (21) MULTI

- COLOR COATING means any automotive coating that exhibits more than one color in the dried film after a single application, is packaged in a single container, and hides surface defects on areas of heavy use, and which is applied over a primer or adhesion promoter

.

(23) (22) PRETREATMENT COATING means any automotive coating that contains a minimum of one

- half (0.5) percent acid by weight and not more than 16 percent solids by weight necessary to provide surface etching and that is specifically labeled and formulated for application directly to bare metal surfaces to provide corrosion
resistance and adhesion

.

(24) (23) PRIMER means any automotive coating , which that is specifically labeled and formulated for application to a substrate to provide 1) a bond between the substrate

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and subsequent coats, 2) corrosion resistance, 3) a smooth substrate surface, or 4)

resistance to penetration of subsequent coats, and on which a subsequent coating is applied. Primers may be pigmented and include weld

- through primers

.

(25 ) (24) SINGLE

- STAGE COATING means any pigmented automotive coating

, ( excluding automotive adhesion promoters, primers and multi

- color coatings ) specifically labeled and formulated for application without a subsequent clear coat coating and applied over primer, adhesion promoters, or color coating . Single

- stage coatings include single

- stage metallic/iridescent coat ings

.

(2 6 ) SPOT REPAIR means repair of an area on a motor vehicle, piece of mobile equipment, or associated parts or components of less than 1 one square foot (929 square centimeters)

.

(2 7 ) TEMPORARY PROTECTIVE COATING means any automotive coating which is specifically labeled and formulated for the purpose of temporarily protecting areas from overspray or mechanical damage

.

(2 8 ) TRANSFER EFFICIENCY means the amount of coating solids adhering to the object being coated divided by the total amount of automotive coating solids sprayed, expressed as a percentage

.

( 29 ) TRUCK BED LINER COAT ING means any automotive coating, excluding color,
multi

- color, and single stage coatings, specifically labeled and formulated for application to a truck bed to protec t it from surface abrasion

.

(3 0 ) UNDERBODY COATING means any automotive coating specifically labeled and formulated for application to wheel wells, the inside of door panels or fenders, the underside of a trunk or hood, or the underside of the motor vehicle

.

(3 1 ) UNIFORM FINISH COATI NG means any automotive coating specifically labeled and formulated for application to the area around a spot repair for the purpose of blending a repaired area’s color or clear coat to match the appearance of an adjacent area’s existing coating

.

Rule 1151 includes an allowance for tertiary butyl acetate (TBAc) for automotive coating
formulation s in which TBAc is considered a non

- VOC except for color coating s and clear coatings . The December 2, 2005 amendment to Rule 1151 included a requirement for a
technical assessment on the use of TBAc as a non

- VOC by July 1, 2007. However, s taff did not find any automotive coatings that contained TBAc to conduct the review and s taff conti nue s to

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review evaluate the issue. Staff recently received correspondence from the Office of Environmental Health Hazards Assessment (OEHHA) indicating that they intend to complete their toxicity review for TBAc towards the end of 2014 or spring 2015 . Sta ff proposes to incorporate OEHHA fin d ings as part of the technical assessment for Rule 1151 with a revised completion date of December 31, 2016 , provided there are automotive coatings that contain
TBAc available to conduct the assessment :

(33) (32) VOLATILE ORGANIC COM POUND (VOC) is as defined in Rule 102

- Definition of TERMS. For the purpose of this rule, tertiary butyl acetate (TBAc) is not a VOC when
used in automotive coatings other than color coatings and clear coatings

. “The Executive Officer s hall conduct a technical assessment on the use of TBAc as a

non

- VOC by July 1, 2007 December 31, 2016

. In conducting the technical assessment, the Executive Officer shall consider all information available to the SCAQMD on TBAc including, toxicity, carcino genic and health risk assessment studies. The Executive Office shall report to the Governing Board as to the appropriateness of maintaining
TBAc as a non

- VOC.”

Definitions to be deleted from Rule 1151
There are three definitions in the current rule that are proposed for delet ion . Definition #9, Cleaning Operations, is proposed to be deleted in favor of definition #24, Solvent Cleaning Operations (moved to maintain alphabetical ordering) . The Solvent Cleaning Operations is a
definition contained with in m any coating rules and it will be proposed for inclusion to Rule 1151
as well for consistency

.

Staff proposes to delete the current definition of CLEANING OPERATIONS in paragraph (c)(9) and replace it with SOLVENT CLEANING OPERATIONS as paragraph (c)(2 5 ).

(9) CLEANING OPERATIONS means the removal of loosely held uncured adhesives, inks, coatings, or contaminants, including, but not limited to, dirt, soil, or grease, from motor vehicles, mobile equipment, associated parts and components, substrates, parts,

p roducts, tools, machinery, equipment, or general work areas.

The second and third d efinition s , #8 and #32

, are not necessary to keep in the rule. Th es e definitions are not use d in other SCAQMD coating rules therefore staff proposes to remove these
definitions for consistency

.

(8) CARB means the California Air Resources Board.

( 32 ) U.S. EPA means the United States Environmental Protection Agency.

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SUBDIVISION (D) REQUIREMENTS In an effort to enhance the understanding of current applicable rule requirements, the proposed amendment seeks to make administrative changes to the rule by removing obsolete rule language, and making minor revisions and editorial corrections

. Paragraph (d)(1)

“

A person shall not apply any automotive coating to a motor ve hicle, mobile equipment, or associated parts or components

, of a motor vehicle or mobile equipment that have a contains
VOC content in excess of the limits contained in Table A of this paragraph in excess of the
limits specified in the Table of Standards below . Compliance with the applicable VOC content limits shall be based on VOC content, including any VOC material added to the original

automotive coating supplied by the manufacturer, less water and exempt compounds, as applie d

, to the vehicle, mobile equipment or parts and components less water and exempt compounds .”

VOC Content Limit Compliance Table The current version of Rule 1151 contains a table in subdivision (d) under the heading of “Table
A

– Coating Categories and VOC limits.” This table shows obsolete VOC limits for several coating categories typically used in automotive coating operations. Staff proposes to reformat the table and show only the current VOC content limits.

TABLE OF STANDARDS

VOC CONTENT LIMITS Gr ams per Liter of Coating, Less Water and Less Exempt Compounds

AUTOMOTIVE COATING CATEGORIES Current Limit

g/L Lb/Gal Adhesion Promoter 540 4.5 Clear Coating 250 2.1 Color Coating 420 3.5 Multi

- Color Coating 680 5.7 Pretreatment Coating 660 5.5
Primer 250 2.1 Single

- Stage Coating 340 2.8 Temporary Protective Coating 60 0.5 Truck Bed Liner Coating 310 2.6 Underbody Coating 430 3.6 Uniform Finishing Coating 540 4.5 Any Other Coating Type 250 2.1

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Paragraph (d)(2)

– Most Restrictive VOC Limit Staff is proposing to make minor revisions by differentiating “ coatings ” as “ automotive coatings ” and making editorial corrections.

“ If any representation on or information on the container of any automotive coating, or any label or sticker affixed to the container, or in any sales, advertising, or technical literature supplied by a person that indicates that the automotive coating meets the definition of or is recommended for use for more than one of the automotive coating categories listed in paragraph (d)(1), then the lowest VOC content limit shall apply .”

Paragraph (d)(3)

- VOC Limits Compliance Dates Paragraph (d)(3) contains a compliance date requirement that has expired. Staff proposes to remove the obsolete rule language and renumber the subseque nt paragraphs in subdivision (d)

.

VOC Limits Compliance Dates The VOC limits in effect as of December 2, 2005 shall be applicable until superceded by the VOC limits and effectives dates in Table A of paragraph (d)(1).

“Paragraph (d)(3)

– Alternative Compliance” (A) Emission Control System

“

A person may comply with the provisions of paragraph (d)(1), by using an approved emission control system, consisting of collection and control devices, that is provided such emission control system is has been approved pursuant to Rule 203

– Permit to Operate , in writing, by the Executive Officer for reducing emissions of VOC. The Executive Officer shall approve such emission control system only if the VOC emissions resulting from the use of non

compliant autom otive coatings will be reduced to a level equivalent to or lower than that which would have been achieved by the compliance with the terms of paragraph (d)(1). [...]

VOC LWn,Max = Maximum VOC content of non

- compliant

automotive coating used in conjunction with a control device, less water and exempt compounds.

D n,Max = Density of VOC solvent, reducer, or thinner
contained in the non

- compliant automotive coating containing the maximum VOC.

D

c = Density of corresponding VOC solvent, reducer, or thinner used in the compliant

automotive coating system = 880 g/L.

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Paragraph (d)(4)

– Exempt Compounds “A person shall not manufacture, sell, offer for sale, distribute for use in the District, or apply

any automotive coating which contains any Group II Exempt Com pounds as defined in Rule
102.”

Paragraph (d)(5)

– Carcinogenic Materials

“

A person shall not manufacture the automotive coatings for use in the SCAQMD in which cadmium or hexavalent chromium was introduced as a pigment or as an agent to impart any property or characteristic to the automotive coatings during manufacturing, distribution, or use of the applicable automotive coatings .”

Paragraph (d)(6)

– Transfer Efficiency Staff is proposing to augment the current language in paragraph (d)(6) by including the term

“ automotive coatings ” and inclu ding additional language for “ application of automotive coatings to a motor vehicle, mobile equipment or any associated parts or components to a motor vehicle or mobile equipment ” . In addition, staff is also proposing new language to address the current

H VLP requirements for spray guns that are used to apply automotive coatings

. (A) A person shall not apply automotive coatings to any motor vehicle, mobile equipment or any associated parts or components to a motor vehicle or mobile equipment except by the use of one of the following methods: (i) electrostatic application, or (ii) high

- volume, low

- pressure (HVLP) spray, or (iii) brush, dip, or roller, or (iv) Spray gun application, provided the owner or operator demonstrates that the spray gun meets the HVLP definition in paragraph (c)(1 7 ) in design and use. A satisfactory demonstration must be based on the manufacturer’s published technical material on the design of the spray gun and by a demonstration of the operation of the spray gun using an air pres sure tip gauge from the manufacturer of the spray gun. ( iii v ) Any such other automotive coating application methods as are demonstrated, in accordance with the provisions of subparagraph (h)(1)( E F

), to be capable of achieving equivalent or better transfer efficiency than the automotive coating application method listed in clause (d)(6)(A)(ii), and for
which provided written approval is obtained offrom the Executive Officer has
been obtained prior to use

.

(B) A person shall not apply any automotive coating s by any of the methods listed in subparagraph (d)(6)(A) unless the automotive coating is applied with properly operating equipment, operated according to procedures recommended by the manufacturer and in compliance with applicable permit conditions, if any. ”

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SUBDIVISION (E) PROHIBITION OF POSSESSION, SPECIFICATION AND SALE
Staff is proposing to make minor revisions to following subdivision by differentiating coatings as automotive coatings and making editorial corrections.

Paragraph (e)(1)

“ For the purpose of this rule, no person that applies automotive coatings subject to this rule
shall posses possess any automotive coating that is not in compliance with requirements of paragraph (d)(1), unless one or more of the following conditions apply: ”

(A) The automotive coating is located for use at a facility that utilizes an approved emission control device pursuant to subparagraph (d)( 4 3 )(A)

, and the coating meets the limits specified in permit conditions.

(B) The automotive coating is located for use at a facility that operates in compliance with an approved Alternative Emissions Control Plan pursuant to subparagraph (d)( 4 3 )(B),
and the automotive coating is specified in the plan.

(C) The automotive coating is located for use at a training center and the automotive coating is used for educational purposes, provided that the VOC em issions from

automotive coatings not meeting the VOC limits of paragraph (d)(1) do not exceed twelve (12) pounds per day.

(D) “The automotive topcoat coating is located for use at a prototype motor vehicle manufacturing facility and the automotive coating is supplied by an assembly

- line motor vehicle manufacturer specifically for use in the refinishing of a prototype motor vehicle, provided that the VOC emissions from all automotive coatings not meeting the VOC limits of paragraph (d)(1) do not exce ed twenty

- one (21) pounds per day and 930 pounds in any one calendar year.”

Paragraph (e)(2)

“ (2) For the purpose of this rule, no person shall solicit from, specify, or require any other person to use in the District any automotive coating which, when applied as supplied or thinned or reduced according to the manufacturer's recommendation for application,
does not meet the: ”

Subparagraph (e)(2)(A)

“ applicable Applicable VOC limits required by paragraph (d)(1) for the specific application
unless:”

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Clause (e)(2)(A)(i)

“ (i) The automotive coating is located at a facility that utilizes an approved emission control device pursuant to subparagraph (d)( 4 3 )(A), and the automotive coating meets the limits specified in permit conditions; or,”

Clause (e)(2)(A)(ii)

“ (ii) The automotive coating is coating is located at a facility that operates in compliance with an approved Alternative Emissions Control Plan pursuant to subparagraph (d)( 4 3 )(B), and the automotive coating is specified in the plan; or”

Clause (e)(2)(A)(iii) “( ii iii ) the The automotive coating is specifically exempt pursuant to subdivision ( i j ) of this
rule.”

Subparagraph (e)(2)(B)

“ the The requirements of paragraphs (d)( 5 4 ) and (d)( 6 5 ) .”

Paragraph (e)(3)

“ No For the purpose of this rule, no person shall supply, sell, offer for sale, market, blend, package, repackage or distribute for use in the District any automotive coating for use within the District subject to the provisions in this rule which, when applied as supplied or thinned or reduced according to the manufacturer's recommendation for application, does not meet the:”

Clause (e)(3)(A)(i)

“ The automotive coating is located for use at a facility that utilizes an approved emission control device pursuant to subparagraph (d)( 4 3 )(A), and the coating meets the limits specified in permit conditions; or, ”

Clause (e)(3)(A)(ii)

“ The automotive coating is specifically exempt under subdivision ( i j ) of this rule; or, ”

Clause (e)(3)(A)(iii)
“The automotive coating is coating is located for use at a facility that operates in compliance
accordance with an approved Alternative Emissions Control Plan pursuant to subparagraph (d)( 4 3 )(B), and the automotive coating is specified in the plan; and,”

Clause (e)(3)(A)(iv) “The person that offers for supplies, sells, offers for sale, markets, blends, packages, repackages sale or distributes the automotive coating keeps the following records for at least five years and makes them available to the Executive Officer upon request:”

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Subclause (e )(3)(A)(iv)(I)

“

Automotive coating Coating name and manufacturer; ”

Subclause (e)(3)(A)(iv)(II)

“

Application method as recommended ; ”

Subclause (e)(3)(A)(iv)(III)

“

Automotive coating Coating category and mix ratio specific to the automotive coating; ”

Subclause (e)(3)(A)(iv)(IV)

“ VOC content of the automotive coating; ”

Subclause (e)(3)(A)(iv)(V)

“ Documentation such as manufacturer specification sheets, material safety data sheets, technical data sheets, or any other air quality data sheets that demonst rate that the material is intended for use as a an automotive coating; ”

Subclause (e)(3)(A)(iv)(VI)

“ Current manufacturer specification sheets, material safety data sheets, technical data sheets, or air quality data sheets, which list the VOC content of each ready

- to

- spray automotive coating (based on the manufacturer’s stated mix ratio) and automotive co ating components and VOC content of each solvent; ”

Subclause (e)(3)(A)(iv)(VII)

“ Purchase records identifying the automotive coating category, name, and volume of

automotive coatings; and ”

Subclause (e)(3)(A)(iv)(VIII)

“ The In addition, f or sale to an end

- user, the name and address of the person purchasing receiving the automotive coating, a statement of the basis an acknowledgement warranting that
the sale to an end

- user purchase will comply with this paragraph, including if use is for outside
the Dist rict

, and acknowledgement by the purchaser that this statement is correct. ”

Subparagraph (e)(3)(B)

“ or does not meet the The requirements of paragraphs (d)( 5 4 ) and (d)( 6 5 ).”

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Paragraph (e)(4)

“ No For the purpose of this rule, no person shall solicit from, specify, require, offer for sale to
, sell to , or distribute to any other person for use in the District any automotive coating application equipment which does not meet the requirements of subparagraph (d)( 7 6

)(A) .”

Paragraph (e) (5) Staff is proposing to add clarifying language to the prohibition of sale requirements for HVLP guns by specifically identifying that the required information to be provided with the sale shall be based on published technical material on the design and demonstration of the air pressure. The demonstration is a requirement for the manufacturer in preparing the required information distributed in conjunction with a sale − it is not intended as a field demonstration prior to each individual HVLP gun sale.

“ No For the purpose of this rule, no person shall offer for sale, sell, supply, market, offer for
sale or distribute an HVLP spray gun for use within the SCAQMD unless the person offering for sale, selling, marketing or distributing the HVLP spray gun for use within the SCAQMD provides accurate information to the spray gun recipient on the maximum inlet air pressure to the spray gun which would result in a maximum air pressure of 10 pounds per square inch

gauge (psig) air pressure measured dynamically at th e center of the air cap and at the air
horns based on the manufacturer’s published technical material on the design of the spray application equipment and by a demonstration of the operation of the spray application equipment using an air pressure tip gauge from the manufacturer of the gun . The information
shall either be permanently marked on the gun, or provided on the company's letterhead or in the form of technical literature which clearly identifies the spray gun manufacturer, the salesperson selle r , or the distributor.”

Paragraph (e)(6)

“ The For the purpose of this rule, the requirements of paragraphs (e)(1), (e)(2), (e)(3) , (e)(4)
or (e)( 4 5 ) or (e)(4) shall apply to all written or oral agreements executed and entered into under the terms of which a n automotive coating or a n automotive coating application equipment shall be used at any location within the District .”

SUBDIVISION (F) RECORDKEEPING REQUIREMENTS Staff intends to clarify the recordkeeping requirements for automotive coatings that are
formulated with TBAc. The proposed definition for VOC allows TBAc in the formulation of

non

- color and non

- clear coatings where TBAc is considered a non

- VOC when deter mining the VOC of the coating for compliance purposes with subparagraph (d)(1). This gives automotive coating manufacturers the ability to formulate non

- color and non

- clear coating s using TBAc to

m e et the VOC requirements in the proposed Table of Standards in paragraph (d)(1). Staff is proposing to make minor revisions to the following paragraph as follows:

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Paragraph (f)(1) Recordkeeping For VOC Emissions “(1) Recordkeeping for VOC Emissions Records of automotive coating usage shall be maintained pursuant to SCAQMD Rule 109

– Recordkeeping for Volatile Organic Compound Emissions, and shall at a minimum include the following information: ”

“ (C) Automotive coating Coating category and mix ratio specific to the coating;

(D) VOC actual Actual VOC and regulatory VOC

, for the automotive coating; (E) Documentation such as manufacturer specification sheets, material safety data sheets, technical data sheets, or any other air quality data sheets that demonstrate that the
material is intended for use as a an automotive coating or solvent; (F) Current manufacturer specification sheets, material safety data sheets, technical data sheets, or air quality data sheets, which list the actual VOC actual for coatings and
VOC regulatory VOC

, for coatings of each ready

- to

- spray automotive coating (based on the manufacturer’s stated mix ratio)

, and automotive coating components used and
the VOC content of for each solvent used; and, (G) Purchase records identifying the automotive coating category, name, and the total volume of all coatings and solvents used

. ”

SUBDIVISION (G) ADMINISTRATIVE REQUIREMENTS Staff is proposing to make minor revisions to following subdivision by differentiating coatings as automotive coatings and making editorial corrections.

Subdivision (g)

– Add Automotive to Coating Manufacturer

“ (g) Administrative Requirements for Automotive Coating Manufacturers ”

Paragraph (g)(1)

– Compliance Statement Requirement

“ For each individual automotive coating, automotive coating component, and ready to spray mixture (based on the manufacturers stated mix ratio), the manufacturer shall include the following information on a product data sheet, or an equivalent medium: (A) The actual VOC and regulatory VOC for automotive coatings (in grams per lit er); ”

Paragraph (g)(2)

– Labeling Requirements

“ (A) The manufacturer of automobile automotive coatings or automotive coating
components , including hardeners

, with the exception of solvents such as reducers and
thinners

, shall include on all containers the applicable use automotive coating
category category(ies) , and the VOC actual VOC and regulatory VOC

, for coatings, as supplied (in grams of VOC per liter of material ) and in grams of VOC per liter of material, less water and less exempt compounds )

. ”

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“ (B) The manufacturer of solvents

, including reducers and thinners

, subject to this rule shall
include on all containers the actual VOC content for solvents, as supplied (in grams of
VOC per liter of material ). ”

SUBDIVISION (H) TEST METHODS Staff is proposing to make minor revisions to following subdivision by differentiating coatings as automotive coatings and making editorial corrections.

Subp aragraph (h)(1)(A)
Add the word “ automotive ” to “ coatings ” : “ VOC Content of Automotive Coatings ”

Clause (h)(1)(A )(i )

“ (i) United States Environmental Protection Agency ( “ U.S. EPA ” ) Reference Test Method 24, (Determination of Volatile Matter Content, Water Content, Volume Solids and Weight Solids of Surface Coatings, Code of Federal Regulations, Title 40 Code of Federal Regulations, Part 60, Appendix A). The exempt compounds’ content shall be determined by South Coast Air Quality Management District ( SCAQM D ) Laboratory

Test Method 303 (Determination of Exempt Compounds) contained in the SCAQMD "Laboratory Method of Analysis for Enforcement Samples" manual; or SCAQMD Method 304 [Determination of Volatile Organic Compounds (VOC’s) in various materials} contai ned in the SCAQMD “Laboratory Methods of Analysis for Enforcement Samples” manual. ”

Staff will be moving reference to test method, SCAQMD Method 304 as a new clause, (h)(1)(A)(ii):

“ (ii) SCAQMD Method 304 [Determination of Volatile Organic Compounds (VOCs ) in Various Materials] contained in the SCAQMD “Laboratory Method of Analysis for Enforcement Samples” manual.”

Subparagraph (h)(1)(B)

– Exempt Perflourocarbon Compounds

. Staff proposes to reformat this rule language to provide the list of classes of compounds in a
semi

- bullet format consistent with other SCAQMD rules

. The following classes of compounds: cyclic, branched, or linear, completely fluorinated alkanes; cyclic, b ranched, or linear, completely fluorinated ethers with no unsaturations; cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations; and sulfur containing perfluorocarbons with no unsaturation s and with sulfur bonds only to

c arbon and fluorine,

“ The following classes of compounds:

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cyclic, branched, or linear, completely fluorinated alkanes; cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations;
and sulfur

- containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine,

shall be analyzed as exempt compounds for compliance with paragraph (d)(1), only at such time as manufac turers specify which individual compounds are used in the formulation of the

automotive coatings and identify the test methods, which have been approved by the U.S. EPA

, CARB and the District SCAQMD prior to such analysis, that can be used to quantify the amounts of each exempt compound .”

Subparagraph (h)(1)(D)

– Add Automotive to Pretreatment Coatings

.

“ (h)(1)(D)

- Acid Content in Pretreatment Automotive Coatings ”

“The acid content of pretreatment automotive coatings shall be determined by ASTM Test

Method D1613

- 06 (2012) (Acidity in Volatile Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, and related products .”

Subparagraph (h)(1)(E)

– Add Automotive to Coatings and be more specific on test method.

“ Subparagraph (h)(1)(E)

- Reflectance of Anti

- Glare Safety Automotive Coatings ” “The reflectance of anti

- glare automotive safety coatings shall be measured determined by

ASTM Test Method D

- 523

- 08 (Specular Gloss) .”

Subparagraph (h)(1) (F)

– Transfer Efficiency

“ The transfer efficiency of alternative automotive coating application methods, as defined by clause (d)( 7 6 )(A)( iii v ), shall be determined in accordance with the SCAQMD method "Spray Equipment Transfer Efficiency Test Procedure for Equipment Use r, May 24, 1989," and SCAQMD “Guidelines for Demonstrating Equivalency With District Approved Transfer Efficiency Spray Gun September 26, 2002 .”

Subparagraph (h)(1) (G)

- Equivalent Test Methods “Other test methods determined to be equivalent after review by the staffs of the District by the Executive Officer , CARB, and the U.S. EPA, and approved in writing by the District Executive Officer may also be used for methods of analysis .”

Subparagraph (h)(2)(A)

– Determination of Efficiency of Emission Control System

“ The efficiency of the collection device of an emission control system as specified in subparagraph (d)( 4 3 )(A) shall be determined by the methods specified in clauses (h)(2)(A)(i), (h)(2)(A)(ii), or (h)(2)(A)(iii)

. below: ”

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Clause (h)(2)(A)(iii)

“ any Any other method approved by the United States Environmental Protection Agency U.S.
EPA

, the California Air Resources Board CARB , and the District Executive Officer .”

Subparagraph (h)(2)(B)

“ The efficiency of the control device of an emission control sy stem as specified in subparagraph (d)( 4 3 )(A) and the VOC content in the control device exhaust gases, measured and calculated as carbon, shall be determined by USEPA Test Methods 25, 25A, or SCAQMD Method 25.1 (Determination of Total Gaseous Non

- Methane Organic Emissions as Carbon) as applicable. U.S. EPA Test Method 18, or CARB Method 422 shall be used to determine emissions of exempt compounds .”

Paragraph (h)(3)

- Multiple Test Methods “When more than one test method or set of test methods are specifi ed for any testing, a violation of any requirement of this rule of this rule documentation established by any one of the specified test methods or set of test methods shall constitute a violation of the rule.”

SUBDIVISION (I)

- RULE 442 APPLICABILITY
Staf f is propos ing to add a new subdivision to the rule to include Rule 1151

- Usage of Solvents
to make Rule 1151 consistent with the other Regulation XI rules that already include Rule 442 applicability language . The new rule language will be under subdivision (i) which will replace
the exemptions subdivision (i)

, and the exemptions subdivision then becomes subdivision (j)

. The new rule language is as follows:

“Rule 442 Applicability Any automotive coating, automotive coating operation or facility which is exempt pursuant to subdivision (j) from all or a portion of the VOC limits of subdivision (d) shall comply with the provisions of Rule 442

– Usage of Solvents.”

SUBDIVISION (J) EXEMPTIONS
Staff is propos ing the following editorial clarifications to the exemptions to the rule requirements

to improve clarity.

“ Paragraph (j)(1)

– This rule shall not apply to: ” (A) Any automotive coating applied to motor vehicles or mobile equipment, or their associated parts a nd components, during manufacture on an assembly line that are is subject to Rule 1115

– Motor Vehicle Assembly Line Coating Operations

. ; ”

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“ (C) Any aerosol coating product; and

(D) Any coating that is sold, supplied, sold, or offered for sale , marketed manufactured, blended, packaged or repackaged for use in the District in 0.5 fluid ounces or smaller

containers.”

Paragraph (j)(2): “(2) The requirements of paragraph (d)(1) shall not apply to automotive coatings applied for educational purposes at automotive coating training centers, which are owned and operated by automotive coating manufacturers, provided that the VOC emissions

emitted at a automotive coating training center from automotive coatings not complying with paragraph (d)(1) does do not exceed twelve (12) pounds per day.”

Paragraph (j)(3): “(3) The requirements of paragraph (d)(1) shall not apply to automotive coatings supplied by an assembly

- line motor vehicle manufacturer for use by a prototype motor vehicle manufacturing facilit y in the finishing of a prototype motor vehicle, provided that the VOC emissions at the prototype motor vehicle manufacturing facility from such

topcoats does do not exceed 21 pounds in a calendar day and 930 pounds in a calendar year.

Paragraph (j)(4)

– E xemptions Paragraph (i)(4) (current rule) contains a compliance date requirement for color and clear coatings that has expired. Staff proposes to remove the obsolete rule language.

“ (j)(4) Color and clear coatings that are manufactured prior to the effective date of July ,1, 2008, that have a VOC content above the limit specified in Table A of paragraph (d)(1), but not above the applicable limit on the date of manufacture may be possessed, sold, supplied, offered for sale, or applied up to December 3 1, 2008. ”

Staff has received ongoing questions about whether or not custom graphics such as pin

- striping,

murals and other special effects type painting are compliant with the transfer efficiency requirements of Rule 1151. Staff reviewed the transfer eff iciency requirements of the SCM and

proposes to align the requirements by adding a new definition for automotive graphic arts operation s and then exempt automotive graphic arts operations, truck bed liner coating operations and underbody coating operation s from the transfer efficiency requirements of subparagraph (d)(6)(A) as follows:

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“(j)(4) The requirements of subparagraph (d)(6)(A) shall not apply to automotive graphic
arts operations , truck bed liner coatings or underbody coatings .”

Proposed Amended Rule 1151 2

- 19 September 2014RULE 1151

– MOTOR VEHICLE AND MOBILE EQUIPMENT NON

- ASSEMBLY LINE
COATING OPERATIONS

CHAPTER 3 : IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1151

ο EMISSION IMPACT ASSESSMENT

ο COST ANALYSIS

ο INCREMENTAL COST

- EFFECTIVENESS

ο CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

ο SOCIOECONOMIC IMPACT ASSESSMENT

ο DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE
407 27

ο COMPARATIVE ANALYSIS

ο DRAFT CONCLUSIONS AND RECOMMENDATIONS

ο PUBLIC COMMENTS AND RESPONSESChapter 3 : Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

EMISSION IMPACT ASSESSMENT Staff does not anticipate any emissions reductions or increases since the proposed amendment
does not change any VOC content limits o r standards and is administrative in nature

.

COST ANALYSIS The proposed amendment to Rule 1151 is not expected to have a net cost impact since industry
will be able to continue business as usual and operate their equipment subject to Proposed
Amended Rule 1151 in a similar manner to the current rule

.

INCREMENTAL COST

- EFFECTIVENESS Under Health and Safety Code § 40920.6, the SCAQMD is required to perform an incremental cost analysis when adopting a Best Available Retrofit Control Technology (BARCT) rule or feasible measure required by the California Clean Air Act. To perform this analysis, the SCAQMD must (1) identify one or more control options achieving the emission reduction objectives for the pr oposed rule, (2) determine the cost effectiveness for each option, and (3) calculate the incremental cost effectiveness for each option. To determine incremental costs, the SCAQMD must “calculate the difference in the dollar costs divided by the differenc e in the emission reduction potentials between each progressively more stringent potential control option as compared to the next less expensive control option.” Staff reviewed the ( October 20, 2005 )

state control measure Suggested Control Measure along with other current standards throughout the state and determined that PAR 1151 represents BARCT for Motor Vehicle And Mobile Equipment Non

- Assembly Line Coating Operations because there are no other more stringent
limits available. PAR 1151 will not result in emission reductions and therefore no incremental cost analysis is required under Health and Safety Code § 40920.6.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) The SCAQMD has reviewed the proposed project pursuant to CEQA Guidelines §15002 (k)(1 )

- General Concepts, the first step of a three

- step process for deciding which document to prepare for a project subject to CEQA. The SCAQMD has determined that that it can be seen with certainty that there is no possibility that the proposed project may have any significant effects on the environment, and is therefore

, exempt pursuant to CEQA Guidelines §15061

- Review for Exemption, paragraph (b)(3)

– “general rule” exemption.

A Notice of Exemption has been prepared pursuant to CEQA Guidelines §15062

- Notice of Exemption. If the proposed project is approved, the Notice of Exemption will be filed with the county clerks of Los Angeles, Orange, Riverside and San Bernardino counties.

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SOCIOECONOMIC IMPACT ASSESSMENT The proposed amendments codify existing practices at Motor Vehicle and Mobile Equipment

Non

- Assembly Line Coating Operations that are subject to Rule 1151. As such, there will be no additional costs or other socioeconomic impacts.

DRAFT FINDINGS UNDER CA LIFORNIA HEALTH AND SAFETY CODE 40727 The draft findings include necessity, authority, clarity, consistency, non

- duplication and reference, as defined in Health and Safety Code Section §40727. The draft findings are as
follows:

Necessity

- The AQMD Governing Board finds and determines that Proposed Amended Rule
1 151, Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations , is necessary to enhance readability and provide clarity of rule language

.

Authority

- The AQMD Gover ning Board obtains its authority to adopt, amend or repeal rules and regulations from Health and Safety Code §§ 40000, 40001, and 40440.

Clarity

- The AQMD Governing Board finds and determines that Proposed Amended Rule 1151
is written and displayed so th at the meaning can be easily understood by persons directly affected by it.

Consistency

– The AQMD Governing Board finds and determines that Rule 1151 is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, or federal or state regulations.

Non

- Duplication

– The AQMD Governing Board has determined that Rule 1151 do es not impose the same requirement as any existing state or federal regulation, and the proposed amendment is necessary and proper to execute the powers and duties granted to, and imposed upon, the AQMD.

Reference

- In adopting this proposed amendment, the AQMD Governing Board references the following statutes which AQMD hereby implements, interprets or makes specific: Health and Safety Code Sections 40001 and 40440.

COMPARATIVE ANALYSIS California Health and Safety Code Section 40727.2 requires the compara tive analysis with any federal or other AQMD rules that apply to the same equipment or source type as the proposed amendments. There are no federal requirements for these small emitting types of equipment sources

.

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DRAFT CONCLUSIONS AND RECOMMENDATIONS
S taff recommends that Rule 1151

- Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations be amended as proposed.

PUBLIC COMMENTS AND RESPONSES The public comments and staff responses shown below are from the May 28, 2014

, public workshop and from the comment letters that were received from May 28, 2014

, through June 6,
2014.

Responses to comments from the public workshop The following comments were made during the public workshop and staff responses to those
comments are shown below.

Comment #1 : The proposed rule language for the purpose of the rule [subdivision (a)] now focuses on the supplier. The focus should remain on the operation and not move to the supplier.

Response: Staff disagrees that the purpose of the rule changed focus and believes the revisions to the purpose

section of the rule [ subdivision (a) ] reflects current implementation of the rule. The rule ’ s purpose is

to reduce volatile organic compound emissions, toxic air contaminates, stratospheric ozone

depleting compounds, and global

- warming compound emissions fr o m automotive coating applications performed on motor vehicles, mobile equipment, and associated parts and components.

Comment #2 : The CARB Consumer Products definition for Aerosol Coating Product and Weld

- Through
Primers should be used in Rule 1151

.

Response: After consultation and concurrence from CARB staff, staff has revised the proposed language to be consistent with the Consumer Products Regulation

.

Comment # 3 : The inclusion of “ Associated Parts and Components ” appears to be overly broad and may loop in

many coatings that otherwise would not normally be considered to be part of an auto refinishing operation, such as the reflective lens coating on a headlight.

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Response: Staff revised the language for the Associated Parts And Components definition by designating

“ coatings ” as “ automotive coatings ” to clarify that the scope of the requirement does not extend to original equipment manufacturer (OEM) applications

.

Comment # 4 : The Clear Coating definition should accommodate materials that don’t impart color that manufacturers loosely refer to as “pigments”, even though they are not technically pigments. Examples include flattening agents and nanopigments.

Response: Staff agrees and has revised the definition for clear coatings as suggested

.

Comment #5 : The commenter recommends removal of Low Volume, Low Pressure ( LVLP ) definition and all
references to LVLP from the proposed amended rule. The commenter said this cou ld open a loop hole and bring many offshore so

- called LVLP PSGs to southern California. There is no way to conduct third party testing on LVLP spray gun s since they are predominantly turbine. The introduction of LVLP technology as an acceptable method ha s downstream effects on literature, training, etc. SATA has a “reduced pressure” gun (exceeds the 10 psig, but has an approved equivalency). SATA would prefer the District maintain the requirement for equipment testing rather than add LVLP as an acceptab le method. Introducing a new method could create a loophole that other gun manufacturers could use to produce guns that may not meet the transfer efficiency requirement s of the rule , but take advantage of either improperly marketed equipment or equipment that would be difficult to test. The commenter inquired if LVLP was a branded
name and wanted to know where the name came from.

Response: LVLP has been around for long time and both CARB and U

. S

. EPA have been using the “LVLP” designation for spray guns for many years. Nonetheless, based on the comment, s taff has removed the LVLP definition from the originally proposed amended rule

, and included a discussion of LVLP
and several other spray gun variants in the staff report. LVLP spray guns must meet the transfer efficiency requirements in clause (d)(6)(A)(iv) or (d)(6)(A)(v) in order to be considered compliant with Proposed Amended Rule 1151.

Comment # 6 : The last sentence in the definition for the Sing le

- Stage Coating definition should be stricken

. The single

- stage coating definition does not appear limited enough to exclude various specialty coatings that do not use a subsequent clear coat (example: underbody coating). Combined with
the more restrictive limit, these specialty coatings would be subject to the single stage coating
limit.

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Response: Staff revised the definition by designating “coatings” as “automotive coatings” and clarifying that these coatings are specifically labeled and formulated for application without a subsequent clear coating and are applied over primer, adhesion promoter, or a color coating

. Staff believes that it is
relev a nt to the definition to keep single

- stage metallic/iridescent coatings and will retain the l ast sentence in the definition.

Comment # 7 : A copy of the 2007 TBAc technical assessment that was due on July 1, 2007 as shown in the December 2, 2005 amendment should be distributed as part of the proposed amendment

.

Response:
The technical assessment that was due on July 1, 2007

, pursuant to the definition for VOC [paragraph (c)(33)] was not conducted because tertiary butyl acetate containing products were not and still are not used for automotive refinishing uses . CEQA staff conducted an offsite analysis on

TBAc as part of the 2005 amendment and found the estimated carcinogenic risk to be five in one million, which is lower than the significance thres hold of 10 in one million for CEQA. The December 2, 2005 amendment to Rule 1151 included a requirement for a technical assessment on the use of TBAc as a non

- VOC by July 1, 2007. However, staff did not find any automotive coatings that

contained TBAc t o conduct the review and staff continues to review the issue. Staff proposes to incorporate another technical assessment for Rule 1151 with a revised completion date of December 31, 2016, provided there are automotive coatings that contain TBAc available to conduct the

assessment.

Comment # 8 : If no one is using TBAc why not just remove it from the rule entirely.

Response:

T

he allowance for TBAc was set in place to provide formulation options to facilitate achievement of VOC content limits and meet consumer demands in a flexible manner

. See also response to comment

# 7.

Comment # 9 : (d)(1) refers to VOC content limit, “...including any VOC material...”. Because t he VOC content is dependent on as applied, which includes both VOC containing materials and non

- VOC containing materials , the term “ VOC material” should be changed to “material”

.

Response: Staff agrees and p aragraph (d)(1) has been revised accordingly

.

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Comment # 10 : The first sentence in paragraph (d)(2) reads , in part, “ If any representation on information... ” but
it should be changed to read “ If any representation on of information... ”

. In addition, the text “supplied by a person” should be removed from the paragraph because it is not necessary.

Response: Staff incorporated the following revision into paragraph (d)(2) “If any representation on or information...”. Replace the word “on” with the word “or”. The text “supplied by a person”
has been removed

.

Comment # 11 : T he transfer efficiency methods in paragraph (d)(6) should be consistent with other Regulation XI rules and include roller and brush methods. Hand application (brush, roller, wipe) should be included as part of the compliant methods under the transfer e fficiency section (especially for components, which can be dip coate d or coated with a hand wipe).

Response: Staff referred to the state S uggested Control Measure (SCM) and found that brush, dip, or roller application methods were listed as suggested coating application methods. Therefore, staff will
include brush, dip and roller application methods to paragraph (d)(6) transfer e ffic i ency to further align with the SCM

.

Comment # 12 : The proposed language for HVLP flow rates is too high. Actual spray gun performance
represents much lower flow rates for HVLP spray guns. Field verification would be challenging.

Response:
The flow rate values have been removed from the proposed amended HVLP definition. If the spray gun manufacturer can demonstrate that a pressure feed spray gun can meet the transfer efficiency requirement pursuant to Rule 1151 Paragraph ( h )( 1 )( F ) or (h)(1)(G) and these type spray guns operate with a air atomization pressure of no more than 10 pounds per square inch at the center of the air cap and at the air horns, they would be an acceptable spray gun to apply automotive coatings

.

Co mment # 13 : Recordkeeping under (e)(3)(A) would be difficult for upstream distributors and manufacturers for tracking coating use as compared to “ intended for use ” or “ specified ” or “ marketed for use ”

, and the words “as recommended” should be added to (e)(3)(A)(iv)(II) for additional clarity . In addition, the requirement to maintain documentation that “a material is a coating” is unclear , and the “documentation” itself required for subparagraph (e)(3) (A)(iv)(V) and (f)(1)(E) is also

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unclear

. A distributor removed from the final sale to an end user may not know or realize that the requirements in (e)(3)(A)(iv)(VIII) apply to them.

Response:
The documentation that a material is a coating is to confirm the material was intended for use as an automotive coating . D ocumentation could include the technical data sheets or the MSDS. Subclause (e)(3)(A)(iv)(V) and subparagraph (f)(1)(E) has been expanded to refer to manufacturer specification
sheet s, material safety data sheets, technical data sheets or any other air quality data sheets that demonstrate that the material is intended for use as an automotive coating The requirements of (e)(3)(A)(iv)(VIII) has been updated to limit the applicability to sale to an end user. Staff has also incorporated the additional clarifying language related to “ intended for use ” and “ for use ” as indicated by your comment.

Comment # 1 4 : (e)(3)(A)(i) should be changed from “ The automotive coating is located at a ... ” to “ The automotive coating is located for use at a... ”

. In addition for (e)(3)(A)(iii) t he proposed rule language shows “The automotive coating is located at a ...” which should be changed to “The automotive coating is located for use at a...”. The words “as recommended” should be added to (e)(3)(A)(iv)(II) for additional clarity.

Response: Staff has included the suggested revision to the proposed amended rule.

Comment # 1 5 : The wording of paragraph (g)(2)(A) referring to components can include thinners, reducers, and
other solvents , although s olvents are not defined in the rule. In addition, components do not
have a coating category. The labeling requirement under (g)(2)(A) for automotive coating components to include the applicable use coating categories may be too exhaustive for thinners or reducers (which are defined as components).

Response: In follow up discussions in regard to this topic, staff revised the rule language in subparagraph (g)(2)(A) and proposes to add new language to exclude solvents such as reducers and thinners from the labeling requirements for identifying automotive coating s or automotive coating component categorie s.

Responses to comments after the public workshop The following comments were made after the public workshop prior to the June 6, 2014

, deadline and staff responses to those comments are shown below.

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Comment # 1 6 {Institute for Research and Technical Assistance} : I am writing with comments on the proposed changes to Rule 1151 “Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations.” I am Director of the Institute for Resear ch and Technical Assistance (IRTA), an environmental technical nonprofit organization that develops and demonstrates low

- VOC, low toxicity alternatives, primarily in solvent applications. Rule 1151 has included an exemption for tert iary

- butyl acetate (TBA C) from VOC regulations for many years.

TBAC forms a metabolite, tert

- butyl alcohol (TBA), which is a carcinogen. Several years ago, the Hazard Evaluation System and Information Service (HESIS) calculated the risk to workers using TBAC at the current Occupational Safety and Health Administration (OSHA) PEL of 200 ppm and provided the results to the California Air Resources Board (CARB). IRTA supplied the calculation to the District staff during an earlier proposed modification for SCAQMD Rule 1107.

T he values show that the risk posed to workers when the TBAC level is at the PEL is estimated at between 74,000 in one million and 380,000 in one million. The District also has information from the Office of Environmental Health Hazard Assessment (OEHHA) s tating that OEHHA stands by a toxicity evaluation they conducted in 2006 for CARB that concluded TBAC should be considered a potential human carcinogen.

SCAQMD Rule 1168 “Adhesive and Sealant Applications” is currently being amended by staff.
The rule or iginally included a proposed exemption for TBAC from VOC regulations. Based on the recent information from OEHHA and the SCAQMD CEQA staff’s risk calculations for on

site workers, off

- site workers and surrounding community members, the proposed exemption was removed from the rule. The risk values demonstrated that TBAC poses a high risk in all

cases.

In 2005, when Rule 1151 was last amended, the rule included a requirement that the District staff perform a technology assessment in 2007 to reassess the r isk from TBAC and to determine if the exemption was still needed. I am requesting a copy of that assessment. The technology assessment that was conducted in 2007 may not have taken into account the OEHHA evaluation
of TBAC that was available at the time. At this stage, given OEHHA’s recent letter reaffirming toxicity of TBAC and the fact that use of the chemical in any application poses a high risk, the District should remove the exemption in Rule 1151 during this amendment process.

The exemption in Rul e 1151 applies only to auto body primers and the District staff has indicated over the last few years that no or very few suppliers rely on TBAC in their coatings. Since this is the case, there are clearly non

- TBAC primers available to the industry and th ey are apparently widely used. This further demonstrates there is no need for the exemption.

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The District’s mission is to protect public health. The exemption for TBAC in Rule 1151 clearly does not protect the health of workers who use it or off

- site wo rkers and community members who are in the vicinity of the operations. I am requesting that the District eliminate the exemption from the rule.

Response: During the rulemaking efforts for the December 2, 2005 rule amendment, CEQA Staff conducted an offsite analysis on TBAC and found the estimated carcinogenic risk to be five in one million, which is lower than the significance threshold of 10 in one million for CEQA. S taff provided a limited use for tertiary Butyl Acetate ( TB A c) for the primer category however at that time no known TBA c containing primers had been identified. The December 2, 2005 amendment for Rule 1151 considered

TBA c to be a VOC only for color and clear coatings

. The purpose of this amendment is administrative; it entails the removal of the obsolete rule language in the first part of the rule that sunset on June 30, 2008 and clarifications to the existing rule language in Appendix A, which

continues as the effect ive portion of the rule.

The technical assessment was to have been conducted by July 1, 2007 . However, staff did not find any coatings that were formulated with TBAc in order to conduct the assessment

. S taff plan s to conduct a future technical assessment on the continued use of TBAc in automotive coatings, with the excluded exception of color and clearing coatings

. Staff recently received correspondence from the Office of Environmental Health Hazards Assessment (OEHHA) indicating that they intend to

comp lete their toxicity review for TBAc towards the end of 2014 or early 2015 . Staff proposes to incorporate OEHHA finings as part of the technical assessment for Rule 1151 with a revised completion date of December 31, 2016, provided there are automotive coatings that contain TBAc
available to conduct the assessment.

Comment # 1 7 { DeVilbiss Automotive Finishes} : Thank you for sending me copies of PAR

- 1151. I have reviewed the proposed changes and have one area I would like to offer some input. In the definition section, you have added additional
info for HVLP.

HIGH

- VOLUME, LOW

- PRESSURE (HVLP) means spray application equipment that has a typical volume flow rate between 30 to 200 cubic feet per minute (cfm), and is designed to atomize 100% by a ir pressure only and operated between 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing pressure measured dynamically at the center of the air cap and at the
air horns.

In this definition, you state that HVLP typical air flow is between 30 to 200 cubic feet per minute (CFM). From my experience, this is air flow rate is extremely high. I have reviewed some of our test data for various HVLP spray guns, both ones that we manufacture, as well as some of our

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competitors, and have listed this info below. In general, full size HVLP guns have an air flow rate between 10 and 20 SCFM and touch HVLP guns have a flow rate between 5 and 10 SCFM. I have seen some HVLP set ups use up to 25 SCFM in the past, but anything more than this starts
to be a lot of air, and most compressors in the body shops would have a problem of maintaining the necessary air pressure to maintain the performance.

Perhaps you have pulled this air flow range from manufacturer’s data that make HVLP guns that are supplied by air turbi nes, not shop compressed air. Many years ago, when DeVilbiss had an HVLP gun that was supplied by an air turbine, I discovered that many of the manufacturers of air turbines had very misleading technical data. They would list the maximum pressure and the maximum air flow the air turbine is capable of producing. These ended up being 2 points on a graph, the maximum air flow was at zero pressure, and the maximum pressure was a zero air flow. The only gun listed below that I have test data on that is suppli ed by an air turbine was the Accuspray 10G. As you can see from this, they are in the typical 10 to 20 SCFM air flow range.

Also, you give the units as cubic feet per minute (CFM). When measuring air flow through a spray gun all air flow should be correc ted to standard temperature and pressure. The units are
then SCFM.

I would recommend that the air flow rate for HVLP be changed in the definition of HVLP. 10 to 20 SCFM would be typical for most full size spray guns. I believe that the definition of LVLP would still be valid, as they typically have less air flow than HVLP.

Response: Staff has revisited the initially proposed new language and proposes to maintain just one compliance parameter based on the dynamic air pressure measured at the center o f the air cap and at the air horns. Staff reviewed several HVLP spray guns and found the volume flow rates typically vary between 10 and 15 standard cubic feet per minute (scfm) and has removed the volume flow rate values from the proposed amended rule de finition . Additionally, Staff has remove d the proposed definition for Low Volume, Low Pressure ( LVLP ) from the proposed amended rule and has provide d a detailed discussion of LVLP, Reduced Pressure and Pressure fed spray guns in the Staff Report and
the tran sfer efficiency requirements based on the dynamic air pressure measure d at the center of the air cap and at the air horns.

Comment # 1 8 {SATA GmbH & Co, KG} : Proposed new definition of “HVLP” atomization technology

– as per § (c)(17):

At present, the term “HVLP” is only defined by one parameter, namely dynamic air cap PRESSURE of max. 10 psi. With the proposed new definition of the term “HVLP”, a SECOND, ADDITIONAL, parameter would be added, i.e. the AIR FLOW RANGE between 30 to 200 cfm.

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First consequence: ALL currently existing HVLP SPRAY GUNS used in the collision repair industry would become ILLEGAL, If the new “HVLP” definition came into force. Why?

– Because all current HVLP spray guns are operated with max. 15 cfm or less.

Second consequence: Spray guns complying with the new “HVLP” definition would be afflicted by a dramatically reduced “Transfer Efficiency (TE) leading to MUCH HI GHER AIR POLLUTION. Why?

– Because the much higher air flow will lead to much higher overspray and consequently to that much lower TE.

Third consequence: ALL collision repair paint materials currently available in the market can no longer be applied with spray guns complying with the new “HVLP” definition. Why?

– Because the application will be extremely dry leading to totally unacceptable, absolutely non

- sellable finishes, due to the high air flow volume.

Fourth consequence: ALL technical data sheets (TD S) of the paint industry and ALL training manuals / training procedures / training certificates of the paint industry as well as of education
bodies such as I

- CAR would become obsolete from one day to the next. Why?

– Because ALL documentation and procedu res will not be in compliance with new “HVLP” term and consequently would have to be adapted in the next step.

Addition of “LVLP” atomization technology complementing the new definition of “HVLP” atomization technology

– as per § (c)(18)”

A newly introduc ed “LVLP” atomization technology as per proposed definition, i.e. dynamic air cap pressure of max. 10 psi and an air flow range of 13.5 to 130 cfm (i.e. 45% to 65% of the above 30 to 200 cfm) would WIDELY OVERLAP with the air flow range of the new “HVLP”
d efinition.

First consequence: As soon as any “LVLP” labeled gun is operated with more than 15 cfm air flow, ALL of the above mentioned four consequences will also become effective.

Second consequence: MOST of the current HVLP spray guns would become illega l. Why?

– Because MOST of the current HVLP spray guns are operated with an air flow which is lower
than 13.5 cfm.

Approval of use of non

- “HVLP” and non

- “LVLP” spray guns as they are defined by the new proposed RULE 1151 legislation

- see § (d)(6)(A)(iv )

Based on the new proposed RULE 1151 legislation, there are currently NO HVLP SPRAY GUNS available on the market which can be used as a benchmark for the SCAQMD approval process as currently existing and known.

First consequence: There is NO POSSIBILITY t o OBTAIN APPROVAL FOR COMPLIANT GUNS anymore.

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Second consequence: ALL existing COMPLIANT SPRAY GUNS will become ILLEGAL, as ALL existing APPROVALS will become INVALID.

Conclusions: The proposed amendments will cause undue burdens and incalculable risks fo r

t he painters

t he bodyshops

t he paint manufacturers

t he spray gun manufacturers

a nd SCAQMD as rule

- executing and monitoring body. The proposed amendments will not improve but

– on the contrary

– will negatively impact on the environmental protection, due to higher, not lower pollution.

The proposed amendments will not only affect the SCAQMD mandated area, but ALL other mandated areas, counties and states in the USA as well as the national 6H EPA RULE, with the SCAQMD approvals being the reference for all o ther approval processes.

The proposed amendments will also obsolete the current definition of terms “HVLP” and “Transfer Efficiency” as currently being used as an official standard terms on a WORLDWIDE basis for almost 26 years.

Response : Please see response to Comment # 1 7

.

Comment # 19 (a) & (b) {SATA GmbH & Co, KG} : SATA recommendations in regard to spray guns and coating application:

The current regulations of RULE 1151 in regard to spray guns and coating application must basically remain unchanged

– as it is an accepted applicable and proven standard in the collision repair industry

– with two exceptions:

a. The exemptions as listed in (i)(1) should be amended with an additional section (C):

SPOT REPAIR [as defined in (b)(41)].

Reason: The material consumption and the level of pollution created by overspray depend primarily on the size of the spot repair area with almost no influence from the spray gun employed.

b. The exemptions as listed in (i)(1) should be amended with an add itional section (D):

PRESSURE FED SPRAY GUNS FOR COMMERCIAL VEHICLES.

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Reason: The material consumption and the level of pollution created by overspray depend primarily on the spraying distance. In addition, there is no affordable and practically working
d evice available to monitor and control the material flow pressure on the gun during application. These issues are the very reason why it has not been possible to approve any pressure fed spray gun according to § (e)(4)(A)(iii).

Response (a):

Elimin ating the transfer efficiency requirement for all spot repair operations would be considered backsliding on emissions reductions. Both the EPA and CARB have legislation requiring air pollution control districts and the air quality management districts to require HVLP application equipment for air atomization for all automotive coatings products. The EPA’s Control Techniques Guidelines for Automobile and Light

- Duty Truck Assembly Coatings and CARB’s the state Suggested
Control Measure both recommend that the air pollution control districts and air quality management
district s require transfer efficiency requirements for spray application equipment for all automotive coating products. Rule 1151 has had the HVLP requirement for spray guns as far back as the December 9, 1994

, amendment. Spot repair and panel repair operations are the bulk of automotive collision repair work in the South Coast Air Basin and this is where the bulk of the VOCs are generated by each automotive collision repair shop. Staff belie ves that regulating spot repair operations by requiring high transfer efficient processes is necessary for ongoing VOC reductions.

Response (b): Staff disagrees because exempting pressure fed spray guns for the transfer efficiency requirements
that are used for larger scale commercial vehicles like buses, tractor truck and trailers and railcars would be considered backsliding on VOC emission reductions. For the reasons expla i ned in staff response (a), s t aff believes the transfer efficiency requir ement for pressure fed spray guns is necessary for VOC reductions . Furthermore, Rule 1151 has requir ed HVLP as far back as the December 9, 1994 amendment when staff introduced HVLP as a significant strategy in th e reduction of VOC emission sources in the South Coast Air Basin

.

Comment # 2 0 {American Coatings Association} : Since this rule is administrative in nature our comments on the proposed changes are in line with this stated purpose. Since the OE H HA review of TBAc is still underway, we agree with SCAQMD that this is not the appropriate time to discuss expanding or restricting the existing exemption. If SCAQMD intends to expand the scope of the rule to include additional coating categories we resp ectfully request that the established “Cavity Wax” category be considered.

Response: Staff does not intend to expand the scope of the rule to include additional coating categories as part of this amendment, which is primarily administrative and aime d principally to remove obsolete

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language and rule clarification

. Staff amended Rule 1151 on December 2, 2005

, to implement the

state S uggested Control Measure (SCM) for automotive coatings. The EPA issued their Control Techniques Guidelines (CTG) for automobile and light duty truck assembly coatings in September 2008. In that CTG, the EPA provided suggested VOC content limits for several misce llaneous coatings which include cavity wax. However, these are suggested VOC content limits for automobile and light duty truck assembly coatings, which are conducted in automobile and light duty truck manufacturing facilities. Rule 1151 does not apply t o automobile and light duty truck assembly operations; Rule 1115

– Motor Vehicle Assembly Line Coating Operations specifically applies to this type operation. Rule 1151

– Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations applies to t he industry that repairs such vehicle after they have been sold by the manufacturers. Staff believes that the underbody coating category effectively captures cavity wax type applications and allows a VOC content limit of no more than 430 grams per liter [ 3.6 pounds per gallon] of VOC.

Comment # 2 1 {American Coatings Association} : In section (a) Purpose, the change from "...from coatings operations associated with the coating of motor vehicles...." to "...from coating applications on motor vehicles..." changes the applicability of the rule from the coating operation to the coating itsel f. Historically, SCAQMD Rule 1151 has applied to the use of coatings in an auto body shop. This change places the requirements of Rule 1151 on the manufacturer of the coating. Although, manufacturers of auto refinish coatings often provide training to e nsure proper use, it is impossible to ensure these products are used as instructed, as body shops are independent from the coatings manufacturer.

ACA requests that SCAQMD retain the current language “...from coatings operations associated
with the coatin gs of motor vehicles...” in the purpose section.

Response: Please see response to Comment # 1

.

Comment # 2 2 {American Coatings Association} : ACA suggests that SCAQMD align the definition of Aerosol Coating Product with the CARB
Aerosol Products Regulation definition.

Response: The proposed language has been updated to reflect the updated definition in the consumer products regulation

.

Comment # 2 3 {American Coatings Association} : ACA believes that the proposed changes to the automotive coating definition expand the scope
of the rule and are inconsistent with the state SCM for automotive coatings. For example,

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terming an auto motive coating “any material” could expand the rule to include products that are applied and “form a film” but are removed (e.g. car wax). The choice of word “material” could be confusing since other jurisdictions (including Sacramento Metropolitan Air Qu ality Management District) have a separate category of “vehicle materials” that include cavity wax, gasket sealer, deadener, and lubricating wax. In order to remain consistent with CARB and avoid confusion with other jurisdictions ACA suggests that the cu rrent definition of “automotive coating” remain intact.

Response:
The word material has been removed from the proposed definition for “ Automotive Coating”

, consistent with the SCM

.

Comment # 2 4 {American Coatings Association} : A clear coating may contain pigments, but the pigments do not impart color. Therefore, ACA
recommends that the definition be revised to read as follows:

“CLEAR COATING means any automotive coating that contains no pigments that impart color that is specifically labeled and formulated for application over a color coating or clear coating.”

Response: Staff ha d several discussions with stakeholders , including CARB, over the issue that a clear coating may have pigments that do not impart color. Staff believes t hat the add ed language that the clear coating may have pigments that do not impart color does not change the meaning of the definition. Therefore staff has revised the proposed language accordingly

.

Comment # 2 5 {American Coatings Associatio n} : The definition of single

- stage coating is extremely broad and given the “most restrictive VOC limit” requirement the definition should be amended to exclude coatings that may meet the
definition of a “ single

- stage coating” but are properly classified under another coating category. ACA recommends the definition of single stage coating read as follows:

“SINGLE STAGE COATING means any pigmented automotive coating, excluding, for example, primers, multi

- color coatings, and any coatings specifically covered by a defined coating category. ”

Response:
Based on discussions with CARB , staff has revised the proposed amended definition for single

- stage coating as follows:

“SINGLE

- STAGE COATING means any pigmented automotive coating, excluding automotive adhesion promoters, primers and multi

- color coatings, specifically labeled and formulated for

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application without a subsequent clear coating and are applied over primer, adh esion promoter, or

a color coating. Single

- stage coatings include single

- stage metallic/iridescent coatings.”

Comment # 2 6 {American Coatings Association} : ACA suggests that SCAQMD align the definition of Weld

- Through Primer with the CARB
Aero sol Products rule definition.

Response:
Based on discussions with CARB

, staff believes that the definition for Weld

- Through Primer from the CARB Aerosol Products Regulation is applicable

. H owever, consistent with other comments concerning applicability, staff proposes to qualify weld

- through primers as those that are used as an automotive coating

.

Comment # 2 7 {American Coatings Association} : ACA suggests that the following language be added to section (d)(1):

“...Compliance with the applicable VOC content limits shall be based on VOC content, including an y VOC material or non

- VOC material (e.g. solids) added to the original automotive coating s upplied by the manufacturer, less water and exempt compounds, as applied to the motor vehicle, mobile equipment or associated parts or component.”

Response: Please see response to Comment # 9

.

Comment # 2 8 {American Coatings Association} : Due to complexities in the distribution chain it is unlikely that a coating manufacturer sells automotive coating products directly to the end user (auto body shop). Consequently, the seller is not aware of a multitude of provisions that must be met to b e in compliance with Rule 1151, notably the application method (see section (e)(3)(A)(vi)(II)). ACA also suggests changing the language in section (e)(3)(A)(i) & (iii)“...located in a facility...” to “...for use at a facility...”
ACA would like clarification in the rule language regarding what type(s) of documentation would satisfy section (e)(3)(A)(iv)(V).

Response: The requirements of subparagraph (e)(3)(A) only apply to sales of materials intended for use in the
District that do not meet the VOC content limits of the rule. Sales of compliant material into the District for use in the District are not subject to subparagraph ( e )(3)(A). Consistent with other SCAQMD VOC rules, the seller is responsible for validating compliant sales

, including compliant

sa les to end

- users , of otherwise non

- compliant materials in to the District for use in the District.

Please also see response to Comment # 13

.

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Comment # 29 {American Coatings Association} : ACA suggests that section (g)(2)(A) be amended to read as follows: “The manufacturer of automotive coatings or automotive coating components shall include on all containers the applicable use category(ies), and the actual and regulatory VOC for automotive coatings, as supplied (in grams per liter), except solvents, and hardeners. Additionally, Section (g)(2)(B) should be amended to include hardeners.

Response: Staff agrees that subparagraph (g)(2)(A) could benefit from additional clarity and will specifically identify the applicable use category(ies) as applicable use automotive category. The revised rule language is as follows: “The manufacturer of automotive coatings or automotive coating
components including hardeners , with the exception of sol vents such as reducers and thinners

, shall include on all containers the applicable use automotive coating category, and the actual VOC and regulatory VOC content, as supplied (in grams of VOC per liter of material and in grams of VOC per liter of material, less water and exempt compounds ) ”.

Comment # 3 0 {American Coatings Association} : If SCAQMD intends to expand the scope of the rule to includ e additional coating categories, ACA respectfully requests that the established “Cavity Wax” category be considered. While the product may meet the definition of an Underbody Coating because the product is used in/on these areas it is not an Underbody Coa ting. Underbody coatings are meant to resist mechanical abrasion as the vehicle is used. Cavity Wax, on the other hand, provides corrosion protection to the main parts of the vehicle. The level of corrosion protection cavity wax provides is needed to

res tore a vehicle to its original factory condition.

It is important to note that although a vehicle may be operated in California today (in this case in SCAQMD), it may not be there for the life of its operation. Corrosion protection is not only
critical f or outer panels (fenders and doors) but is also important for structural members that have been replaced. Failure to properly protect internal sections of welded steel panels subjects them to corrosion, which may compromise structure and safety. This is an issue of passenger safety and maintaining corrosion protection even if the car leaves California for another jurisdiction.

There are aerosol versions of this product covered by the Aerosol Coatings Rule currently
available in California. The aerosol v ersion of the product does not provide adequate coverage for the hard to reach parts of the vehicle that require this type of protection. The aerosol product does not provide a 360 degree pattern that the liquid product does. The tool used with the liqui d product allows the product to cover hard to reach places in the vehicle like frame rails, which are imperative to safety. The tool is a long thin hose that can get to hard to reach places of the

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vehicle and provide a large enough volume to provide corro sion protection. The aerosol version
cannot do this.

Response: Please see response to comment #20.

Responses to additional comments after the public workshop The following additional comments were submitted following the June 6, 2014 deadline and staff responses to those comments are shown below.

Comment #31 : After reading the Rule 1151, version 9, and an intensive discussion with SATA`s independent importer in the US (Dan Am, Spring Valley) we do have some comments and suggestions for changes in regard to the amended § (c)17, (d)(6)(A) and (d)(6)(A).

A. Page 4, § (c)17 (as presently amended) High

- Volume, Low

- Pressure (HVLP means spray application equipment designed to atomize 100% by air pressure only and is operated bet ween 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing pressure measured dynamically at the center of the air cap and at between the air horns.

The attached picture shows a test air cap with gauges in the center of the air cap as well in one o f the horns very close to the horn air outlet bore to measure the internal air cap pressure in the center as well in the horns (test air cap commercial available in the market). If the gauge would be positioned between the horns as amended, than this gauge would be located in the center of the air cap also. With such kind of test air cap nobody would be able to measure the internal air cap horn pressure. The gauge have to be still located at the horn.

Therefore this §(c)17 should be remain as before valid a nd should read: (....) atomizing pressure measured dynamically at the center of the air cap and at between the air horns.

Response: Staff agrees and will rev ise the definition to show “...measured dynamically at the center of the air cap and at the air horns.”

B. Page 10, § (d)(6)(A) (as presently amended) A person shall not apply automotive coatings to any motor vehicle, mobile equipment or any associated parts or components to a motor vehicle or mobile equipment except by the use of one of the following metho ds:

(ii) high

- volume, low pressure (HVLP) spray, or

(iv) Spray gun application, provided the owner or operator demonstrates that the spray gun meets the HVLP definition in § (c)(17) in design and use. A satisfactory demonstration must be based on the manu facturer`s published technical material on the design of the spray gun and by a

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demonstration of the operation of the spray gun using an air pressure tip gauge from the manufacturer of the spray gun.

As in (iv) there is no definition for the air pressure tip gauges (where the gauges have to be positioned at the air cap) and the demonstration for meeting the HVLP requirements have to be done in accordance to §(c)17, we suggest that such kind of air pres sure tip gauge have to have a gauge in the center as well at the horns of the air cap like in the attached picture.

Response: See response to Comment #31A.

C. Page 14, §(d)(6)(A) (as presently amended)

No For the purpose of this rule, no person shall offer for sale, sell, supply, market, offer for sale or distribute an HVLP spray gun for use within the SCAQMD unless the person is offering for sale, selling, marketing or distributing the HVLP spray gun for use within the SCAQMD provides accurate information to the spray gun recipient on the maximum inlet air pressure to the spray gun which would result in a maximum air pressure of 10 pounds per square inch gauge (psig) air pressure measured dynamically at th e center of the air cap and between the air horns based on the manufacturer`s published technical material on the design of the spray application equipment and by a demonstration of the operation of the spray equipment using an air pressure tip gauge from the manufacturer of the gun. The information shall either be permanently marked on the gun, or provided on the company’s letterhead or in the form technical literature which clearly identifies the spray gun manufacturer, the sales person or the distributor

.
In §(e)(3)(B)(5) it is mentioned, the air pressure measured dynamically between the air horns like in § (c)17. Like § (c)17 between have to be deleted and at the horns have to be added in this § in the same manner like in (c)17.

It has to be clarified th at, (....) and by a demonstration of the operation of the spray equipment using an air pressure tip gauge from the manufacturer of the gun. (....), have to be done only via the sales or offering persons of the spray gun manufacturer or spray gun dealers but no t with the end users e.g. painters or body shop owners. If each individual purchase of a spray gun have to be guided with a test air cap, that would bring up a very high economic burden for the painters or body shop owners. It would be a waste of money, as for testing all guns of a body shop there would be need of only one test air cap and not of multiple test air caps.

Response: See response to Comment #31A.

D. Page 20, §(j)(4)(as presently amended)

The requirements of subparagraph (d)(6)(A) shall not apply to any automotive graphic arts operation.

As already suggested in our comments dated June 5th, 2014, this paragraph should extended to spot repair as well (spot repair, see (c)(26)). Reason: The material consumption and the level of possible polluti on created by overspray depend primarily on the size of the spot repair area with

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almost no influence from the spray gun being employed. Therefore this paragraph should be amended as below:

The requirements of subparagraph (d)(6)(A) shall not apply to an y automotive graphic arts operation and any spot repair

.

Response: Both the EPA Control Techniques Guidelines (CTG) and state Suggested Control Measure (SCM) contain the transfer efficiency requirement which does not include an exception for spot repair. The SCAQMD is required to be at least as stringent as CARB and EPA but can never be less stringent. In addition, the applicability to spot repair is a part of the existing rule requirements and relaxation of the requirement would be considered to be backs liding. However, staff has also reviewed the allowances for truck bed liners and underbody coatings and has extended the exemption from transfer efficiency, consistent with the SCM.

Comment #32 {Sherwin

- Williams} : These comments are organized in the same manner as the proposed rule and are based on a comparison of my comments on the previous draft proposed rule to the current draft.

A. Definitions Definitions 5 and 7, automotive coating and clear coating, have been revised, consistent with my

recomme ndations.

Definitions 15 and 16 have been revised, adding the terms “regulatory VOC” and “actual VOC”, which are used elsewhere in the rule and thus, it is helpful to have the terms defined. However, it was my understanding from the initial discussions f or amending Rule 1113, that the District may be going away from the term “regulatory VOC.”

Response: Those preliminary discussions for Rule 1113

– Architectural Coatings are simply considerations until the Board adopts amendments, and specifically include a possible regulatory standard based on “Material VOC’ in place of “Regulatory VOC”. This may be a consideration in future rule making associated with Rule 1151

.

B. I noted that the definition for LVLP, low volume, low vapor pressure, application equipme nt has been removed. Also, the definition for HVLP has been changed and no longer refers to a specific volume: do these two changes still allow the use of LVLP equipment, since no specific volume is defined for HVLP?

Response: LVLP is discussed in detail in the staff report. SCAQMD will consider equivalency (to HVLP) for HVLP variants such as LVLP and LVMP provided these variants meet all the transfer efficiency requirements in Rule 1151. Please also see response to comment #17.

C

. Definition 24

– sing le stage coating

– has been revised and I believe it is now acceptable since it specifies that these coatings are applied over adhesion promoters, primers, or color coatings.

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Thus, there should not be overlap with truck bed liners, underbody coatings, or uniform finish coatings. I am uncertain whether there is overlap with multicolor coatings.

Response: Staff intends to keep the existing language “Single

- stage coatings include single

- stage metallic/iridescent coatings” in the definition for Single

- stage C oatings to be consistent with CARB’s Suggested Control Measure which also includes this language.

D

. Noting that another technical assessment on the use of tBAC is proposed with a completion date of December 31, 2016, the question of whether there will be any additional information by then arises. Perhaps a later date might be more appropriate to insure the data is complete?

Response: Staff anticipates an update from OEHHA by the end of this year in regard to significant toxic risk for TBAc. Staff will t hen determine an appropriate course of action to the finding which may include extending date of technical assessment.

E

. The changes to the definition of weld

- through primer are not acceptable. It is my understanding that weld

- through primers are applie d prior to welding, as the previous definition indicated. I recommend either return to the previous definition, or include in the definition the concept that these coating are applied prior to welding.

Response: Staff discussed the previous definition for “Weld

- Through Primers” with several stakeholders during the May 28, 2014

, public workshop for PAR 1151. The stakeholders requested PAR 1151 use the same definition for “Weld

- Through Primers” as the CARB Aerosol Product Regulation. In subsequent discussio ns with CARB staff, SCAQMD rules staff and CARB staff concluded that the definition used for “Weld

- Through Primers” in the CARB Aerosol Product Regulation was appropriate for use in PAR 1151.

F

. Requirements The revision to section (d)(1) is acceptable, wi th one minor edit to the last sentence: instead of this statement: “Compliance with the applicable VOC content limits shall be based on VOC content, including any material added to the original automotive coating supplied by the manufacturer, less water a nd exempt compounds, as applied to the motor vehicle, mobile equipment or associated parts and components.” It would make more sense to say

“ Compliance with the applicable VOC content limits shall be based on VOC content, including any material added to the original automotive coating supplied by the manufacturer, as applied to the motor vehicle, mobile equipment or associated parts and components, less water and exempt compounds.” Or even “Compliance with the applicable VOC content limits shall be based on VOC content, including any material added to the original automotive coating supplied by the manufacturer, as applied, less water and exempt compounds.”

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Response:
T

he following suggested revision has been incorporated into the proposed amended rule: “C ompliance with the applicable VOC content limits shall be based on VOC content, including any material added to the original automotive coating supplied by the manufacturer, as applied, less water and exempt compounds.”

G

. Section (d) (2)

- Most restrictive Limit Section (d) (2) provides the restriction that when a coating meets more than one definition or is recommended to fit more than one coating category, then the lower limit listed must apply. However, there are certain exceptions which may be needed: pretreatment coatings and weld

through primers seem to meet the definition for primers [that is, they provide corrosion resistance]: are either of these defined coatings supposed to meet 250 g/l limit for primers?

Response: Pretreatment primers are required to be specifically labeled and formulated for application directly to bare metal surfaces to provide corrosion resistance and adhesion. “Weld

- through Primers”

, although having a stand

- alone definition

, for the purposes of this rule are considered to be a subset of the “Primer” category and subject to the Primer VOC content limit. If a material is specifically labeled and formulated for both pretreatment and non

- pretreatment primer use, it would be subject to the more rest rictive limit. Staff does not believe that pretreatment primers would be labeled and formulated for use as a non

- pretreatment primer.

H

. Section (d) (4)

– Exempt Compounds Section (d) (4) needs to be amended to specify automotive coatings. This can be a ccomplished as shown below: “A person shall not manufacture, sell, offer for sale, distribute for use in the District, or apply any automotive coating which contains any Group II Exempt Compounds as defined in Rule 102.”

Response: Staff has included the su ggested revision to the proposed amended rule.

I

. Section (e) (3) (A)

– Prohibition of Sale of Noncompliant Coatings Section (e) (3) (A) (iv) (VIII) prohibits the sale of noncompliant coatings unless certain provisions are met. Subpart (iv) (VIII) provide s the requirements when sale is to an end user. It requires the name and address of the person receiving the noncompliant automotive coating and the basis upon which the sale is being made, and a statement that the statement made by the end user about thi s basis is correct. This paragraph could be clarified by removing the supply and distribution concepts: it should be sufficient to simply cover “for sale to end users.” [In addition, receiving was spelled incorrectly.]

Response: Staff has included the suggested revision to the proposed amended rule.

J

. Section (f) (1) (E)

– Recordkeeping Section (f) (1) (E) covers recordkeeping and still requires we provide documentation that demonstrates the material is an automotive coating. The documentation liste d may state that a coating is an automotive coating, or may imply it by the directions for use. However, such

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documentation will not really demonstrate that a coating is an automotive coating. Perhaps changing the word “demonstrate” to “states” would cla rify the meaning of this paragraph, as follows: “Documentation such as manufacturer specification sheets, material safety data sheets, technical data sheets, or any other air quality data sheets that demonstrate indicate that the material is intended for use as an automotive coating or solvent”

Response: Staff has included the suggested revision to the proposed amended rule.

Comment #33 {American Coatings Association} : A. In the Clear Coating definition, it makes no sense to put a clear over a clear. By changing the definition to a “base” coating, you now could put this over a primer which in not necessarily considered a color coating. ACA recommends the following change:

“CLEAR COATING means any automotive coating that contains no pigments is formulated with materials that do not impart color and is specifically labeled and formulated for application over a color coating or clear base coating.”

Response: Other stakeholders also had concerns that a clear coat wasn’t meant to be applied over a clear coat

w ith the possible exception of applying a clear over a properly prepared weathered clear coat for restoration purposes. Staff revised the definition for clear coating as follows:

“CLEAR COATING means any automotive coating that is formulated with materials that do not impart color and is specifically labeled and formulated for application over a color coating or clear coating.”

Staff believes the current definition for a clear coating captures the intent of what a clear coating is used for. The original de finition for “Clear Coating” in Rule 1151 was mirrored from CARB’s State the state Suggested Control Measure, as approved by their Board on October 20, 2005, and since then all the other Air Pollution Control Districts and Air Quality Management Districts in the state of California have been using the same or similar definition.

B. Under the defin ition of VOC, TBAc is not a VOC when used in automotive coatings other than color coatings and clear coatings. However, under the proposed recordkeeping requirements (f)(1)(D) VOC, actual and regulatory, for the automotive coating, for the purposes of

rec ordkeeping, TBAc shall be considered a VOC for any automotive coating and TBAc shall be included in the VOC, actual and regulatory, for the automotive coating. The way this is phrased, it would bring primers, and all other categories back into treating TBA c as a VOC. ACA recommends the following change: “...TBAc shall be considered a VOC for any automotive coating refinish color coating and clear coating and TBAc shall be included in the VOC, actual and regulatory, for the automotive coating refinish color coating and clear coating .”

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Response: Staff has removed the recordkeeping requirement for TBAc as a VOC to subparagraph (f)(1)(D) of the proposed amended rule based on a follow

- up review of EPA’s evaluation for the 2005
amendment to the rule.

C. Also in the recordkeeping section, under prohibition of sale (see page 13), ACA noted that recordkeeping is being expanded from “...the person that offers for sale, or distributes...” to “...the person that supplies, sells, offers for sale, markets, blends, repackages

, or distributes...” This could impact distribution down the entire supply chain. In particular, inclusion of the term “repackages” could draw in toll processors who might be hired to fill small containers from bulk packages supplied by a coating manufacturer. In that case the toll company would likely be operating under an air permit and their operation is not dependent on whether the product to be repackaged is refinish, deco, AIM, etc. Unless such an operation is “selling” directly to customers (wholesaler s or body shops) which is unlikely, they are simply a toll processor and

should not be covered under the refinish rule.

Response: Please see response to Comment #28

.

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- 24 September 2014References Final Staff Report

REFERENCES

SCAQMD Staff Report, Proposed Rule 11 51

– Motor Vehicle a nd Mobile Equipment Non

Assembly Line Coating Operations

, December 20 05

Websites:
DeVilbiss Automotive Refinishing http://www.autorefinish DeVilbiss .com/aboutus.aspx

Sata GmbH & Co., KG http://www.sata.com/index.php?id=rppistolen&L=11

Sharpe http://www.sharpe1.com/sharpe/sharpe.nsf/Page/RAZOR+LVLP

Spray Gun World http://www.spraygunworld.com/products/ DeVilbiss /Compacts/CompactCViPOutifts.html

Spray Painting http://e n.wikipedia.org/wiki/Spray_painting

The History of Spray guns http://www.bodyshopbusiness.com/issue/article.aspx?contentid+4109

Electrostatic Paint Application http://spraygunindustry.com/Information2/Electro%20Static/Electrostatic%20Start.html http://www.hppindustrialsales.com/pages/accessa.asp

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- 1 September 2014