UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District Rule 1 151

Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

October 2015 2



RULE IDENTIFICATION

-

Agency: South Coast Air Quality Management District

(SCAQMD)

SIP Approved Rule: Rule 1151

- Motor Vehicle and Mobile Equipment Non

Assembly Line Coating Operations

Amended

- December 2, 2005

Submitted

- April 6, 2009

EPA Approved

- September 24, 2013 (78 FR 58459)

Subject of this TSD: Rule 1151

- Mot or Vehicle and Mobile Equipment Non

Assembly Line Coating Operations

Amended

- September 5, 2014

Submitted

- April 7, 2015

BACKGROUND

- According to the Staff Report, “The prior amendment to the rule

was on December 2, 2005, which 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 Rule 1151, identified as App endix 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 pages o f currently

effective rule language, Appendix A. This structure continues to cause confusion

to the regulated community

. ” 1 This amendment makes administrative changes to

the rule to enhance the understanding of current applicable rule requirements by

removing obsolete rule language, the two part structure, and makes minor

revisions and editorial corrections. The amendment also adds new definitions to

promote clarity and consistency, and further aligns the transfer efficiency

equivalency section with the California Air Resources Board’s (CARB) Suggested

Control Measure (SCM). This amendment 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 impacts are

anticipated from this proposal

. 2

RULE SUMMARY

- Rule 1 151 establishes VOC content limits and workplace

standards for motor vehicle and mobile equipment coating operations. It also

describes related recordkeeping, reporting, and monitoring requirements.

Changes from the approved SIP rule include:

1 Final Staff Report, “Proposed Amended Rule 1151

- Motor Vehicle And Mobile Equipment Non

Assembly Line Coating Operations ,” SCAQMD, September 2014.

2 Ibid. 3



1. Removal of the two part structure of the rule.

2. Removal of Group I and Group II class vehicles.

3

. Other minor formatting and editorial revisions to improve clarity.

EVALUATION CRITERIA

- The following criteria were used to evaluate the

submitted rule :

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation

Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little

Bluebook ( Guidance Document for Cor recting Common VOC & Other Rule

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate

compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency

- The Code of Federal Regulations (CFR) Title 40 Subpart B

National Volatile Organic Compound Emission Standards for Automobile

Refinish Coatings (NVOCESARC) §59.102 Standards table 1 (40 CFR

59.102, table 1)

, CARB’s Suggested Control Measure (SCM) titled,

“Suggested Control Measure for Automotive Coatings,” (approved by the

board on October, 2005) and other state and local rules were used to help

evaluate the rule stringency.

3. SIP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision

that would interfere with any applicable requirement concerning attainment

and reasonable further progress (RFP) or any other applicable requirement

of the CAA. In addition, CAA § 193 prohibits the modifi cation of any SIP

approved control requirement in effect before November 15, 1990, in a

nonattainment area.

EPA EVALUATION

–

1. The rule requirements and applicability are clear, and the monitoring,

recordkeeping, reporting and other provisions sufficiently ensure that

affected sources and regulators can evaluate and determine compliance

with Rule 1151 consistently.

2. Since SCAQMD is an e xtreme n onattainment area for ozone, the district

must implement RACT requirements pursuant to CAA section 1 82(b) (2)

. We

believe Rule 1151 fulfils RACT requirements because VOC limits are more

stringent than t he Code of Federal Regulations (CFR) Title 40 Subpart B

National Volatile Organic Compound Emission Standards for Automobile

Refinish Coatings §59.102 Standards table 1 (40 CFR 59.102, table 1 ) and

are equivalent to the limits set forth in CARB’s SCM for Automotive

Coatings. 4



3. We propose to determine that our approval of the submittal would comply

with CAA §§ 110(l) and 193 because (1) the proposed SIP revision would

not interfere with the on

- going process for ensuring that requirements for

RFP and attainment of the NAAQS are met, and (2) the emission limits in

the submitted rule are at least as stringent as the existing SIP

- approved

control requirements that they would replace. Additionally, the proposed

amendment of Rule 1151 is easier to understand because obsolete terms

have been removed and extraneous portions of the rule removed.

RULE DEFICIENCIES

- E PA finds no deficiencies with Rule 1151.

EPA ACTION

– EPA recommends full approval of Rule 1151

.

RECOMMENDATION FOR THE NEXT RULE REVISION

– The following revision

is not the basis for rule disapproval but is recommended for the next time the rule

is amended.

1. To stay consistent with the requirements in CARB’s SCM, consider revising

subsection (d) (3) “Alternative Compliance” (A) “Emission Control System”

and ( d ) (3) (B) “Alternative Emission Control Plan” to state that the required

efficiency of the emission control system as calculated in (d) (3) (A) be a

minimum of 85%.

REFERENCES

- :

1. SCAQMD Rule 1151

, “ Motor Vehicle and Mobile Equipment Non

Assembly Line Coating Operations

, ” EPA Approved

- September 24, 2013

(78 FR 58459)

. 2. SCAQMD Rule 1 151 “ Motor Vehicle and Mobile Equipment Non

Assembly Line Coating Operations

, ” Amended

- September 5, 2014

3. CARB, “ Suggested Control Measure for Automotive Coatings,” October

2005

. 4 The Code of Federal Regulations (CFR) Title 40 Subpart B National

Volatile Organic Compound Emission Standards for Automobile Refinish

Coatings §59.102 Standards table 1 (40 CFR 59.102, table 1 )

. 5. EPA’s Control Techniques Guidelines (CTG) for, “Reductio n for Volatile

Organic Compound Emission from Automotive Refinishing” (EPA

- 450/388

- 009), October 1988.

6

. Sacramento Metropolitan Air Quality Management District Rule 459,

“Automotive, Mobile Equipment, and Associated Parts and Components

Coating Operations, ” EPA Approved

- August 9, 2012, 77 FR 4736.

7

. San Joaquin Valley Unified Air Pollution Control District Rule 4612 “ Motor

Vehicle and Mobile Equipment Coating Operations, ” EPA Approved

- February 13, 2012, 77 FR 7536. 5



8

. Santa Barbara Air Pollution Control District Rule 339, “ Motor Vehicle and

Mobile Equipment Coating Operations ,” EPA Approved

- August 24, 2013,

78 FR 58459.