UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For
EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Antelope Valley Air Quality Management District , Rule 1151 , Motor Vehicle and Mobile Equipment Coating Operations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

September , 201 2- 2

-

Agency: Antelope Valley Air Quality Management District ( AV AQMD)

SIP Approved Rule: Rule 11 51

- Mot or Vehicle and Mobile Equipment Coating Operations
A dopt ed – J ul y 8 , 1988
Amended – July 20, 1999 Submitted
– October 29, 1999 EPA Approval – April 10, 2000 (6 5 FR 18901 )

Subject of this TSD: Rule 11 51

- Motor Vehicle and Mobile Equipment Coating Operations
A mend ed – June 19, 2012 Submitted
– September 21, 201 2

RULE SUMMARY

- AVAQMD Rule 11 51 , Motor Vehicle and Mobile Equipment Coating Operations , is a rule designed to limit volatile organic compound (VOC)
emission s from the coatings and solvents associated with the refinishing of motor vehicles, mobile equipment and their associated parts and components. Section (B), Definitions

, includ es all applicable definitions as well as a table for the term Coating Categories that clarifies coating categories before and after the 5/1/2013 compliance deadline. Section (C)
, Requirements , includes Table 1 that lists VOC limitations for coating s , promoters and sealers on and after 5/13/2013, Table 2 that lists VOC limitations for coatings, prim ers and sealers prior to 5/13/2013, alternative compliance procedures, application methods, surface preparation and cleaning operations and prohibition of possession, specification and sale

. Subsections of Section (C) also indicate the prohibited use of ex empt VOC compounds and carcinogenic materials . Section (D)
, Exemptions , list s types of coating and coating operations exempt from the VOC limits , including assembly line- 3

-

coatings, coating s sold outside the district, coatings sold in small quantities, coati ngs applied for educational purposes and coatings that are r egulated by AVAQMD’s Rule 442. Section (E)
, Administrative Requirements , covers manufacturers’ compliance procedures and labeling and Section (F)
, Recordkeeping Requirements

, indicate requirement s for recordkeeping of coatings and solvents

. Section (G), Test Methods , include approved test methods for VOC content, metallic content, acid content, transfer efficiency, equivalency efficiency as well as other content and efficiency tests. Changes from the approved SIP rule include:
1. In section (A), General , consideration of solvents was added to the rule’s Purpose sub section and s uppliers and appliers , for which the rule is applicable , were added to the Applicability sub section.
2. Several new definitions were added and some definitions were revised for clarification in section (B), Definitions

. 3. In section (C)
, Requirements , the following major changes were made:

a. Group I and II vehicle categories were discontinued and the VOC limits listed by the new coating categories closely correspond to those in the California Air Resources Board (CARB) Suggested Control Measure (SCM) For Automotive Coatings 1 in the Requirements section

. b. Coating categories color and clear multistage categories, a single primer category and specific categories were added , replacing the “general specialty” category. A clarification that the most restrictive limit be applied if a coa ting meets the definition of mul tiple categories was added.

c. A lternative compliance was expanded to include an emission control system approved by the APCO or a plan pursuant to AVAQMD Rule 108, Alternative Emissions Control Plan.

1 . CARB SCM For Automotive Coatings as approved by the Board on October 20, 2005- 4

- d. Select exempt VOC’s are prohibited from manufacture, sale and
distribution.

e. The carcin ogenic materials previously restricted from manufacture are further defined by a California Public Health code 2

. f. Coating applications were increased to include brush, dip or roller, the sale and labeling of High

- Volume, Low

- Pressure (HVLP) spray guns

was more clearly specified and the transfer efficiency of an alternative method was defined as not less than 65%.
g. S olvents for surface preparation and cleaning operations in this rule , work practices for the handling and storage of solvents and the establishm ent of 25 grams VOC per liter limit and were added.
h. The prohibition of possession, specification and sale was expanded to clearly define restrictions of each func tion.
4. The section, Exemptions, was expanded to include exemptions of assembly line coating operations, and to prototype motor vehicle manufacturing facilities with less than 21 lb/day VOC emissions. A provision was added mandating coatings exempt under this rule to comply with AVAQMD’s rule
442.
5. The section, Administrative Requirements , was added to the rule and includes manufacturers’ and re

- packagers’ compliance statements and labeling requirements. 6. The Recordkeeping section was expanded to include a listing of coatings
and solvents , a daily record of coatings and a monthly record of cleaning
solvents

. The recording of methylene chloride weight percentage and the five year record retention satisfies the National Emissions Standards for

2 . 17 CA ADC § 93112 Air Toxic Control Measure (ATCM) for Hexavalent Chromium and Cadmium from Motor Vehicle and Mobile Equipment Coatings.- 5

- Hazardous Air Pollutants (NESHAP): Paint Strippi ng and Miscellaneous Surface Coating Operations at Area Sources 3

. 7. All previous test methods were updated to comply with the EPA standard for referencing ASTM’s and other districts’ test methods and test methods for the determination of methyl acetate, acet one and PCBTF, for alternative compliance, for exempt compound content and HVLP equivalency were
added. EPA EVALUATION

- The following criteria were used to evaluate the submitted
rule : 1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to evaluate compliance with the CAA §110(a)(2)(A) requireme nt for enforceability

. 2. Stringency
– EPA’s Control Technique Guidelines (CTG) for , “ Reduction for Volatile O rganic Compound Emissions from Automobile Refinishing ” ( EPA

45 0 / 3

- 88

- 00 9 ) , dated Octo ber 19 88 , Alternate Control Techn iques ( ACT)
Document: “ Automotive Refinishing ” (EPA

- 453/R

- 94

- 031) dated April 1994, Maximum Achievable Control Technology (MACT) “NESHAP Standards f or Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources” (40 CFR 63 Subpart HHHHH H ) , CARB’s Air Toxic Control Measure (ACTM) 17 CA ADC § 93112, “ Hexavalent Chromium and Cadmium Airborne T oxic Measure – Motor Vehicle and Mobile Equipment Coatings ” , CARB’s SCM for Automotive Coatings (approved by the board on October, 2005) and other st ate and local rules for this category were used to help evaluate the RACT requirements of CAA § 182( c )( 1 ).

3 . 40 CFR Part 63, Subpart HHHHHH National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources- 6

-

3. Relaxation – We have evaluated this SIP revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the
Act ( CAA §110(l) ) or modify, in a nonattainm ent area, any SIP

- approved control requirement in effect before November 15, 1990 (CAA §193 )

.

Enforceability

- The recordkeeping, reporting and other enforcement requirements generally ensure that the submitted rule can be implement ed. Examples of this are: 1. VOC’s

- actual and regulatory – are clearly defined with accurate calculations
shown.
2. The rule applicability and exemptions have been expanded and clarified to preclude uncertainty. 3. All VOC limit s have compliance dates and there is a comparison table of previous and current coating categories that assure s that the VOC limits of all of the previous categories have been addressed

. 4. The “Most Restrictive VOC Limit” statement in subsection (C )( 2 )( a) precludes the arbitrary assignment of limits to coatings which may be assigned to more than one category.
5. The alternative control systems and plans are subject to approval by the Air Pollution Control Officer, the position of which is defined. Additio nally, the control efficiency is required to be at least 85%. 6. Recordkeeping requirements for solvents and coatings are clear and unambiguous, with clear and allowable recording timeframes.
7. There are recommended test methods for twelve different coating fa ctors and the non

- EPA methods have full titles and approved version dates. 8. The transfer efficiency for alternate application methods is clearly defined as 65% or more and the determination of the transfer efficiency of the equivalent to HVLP is prescribed by a specific procedure.- 7

-

Monitoring criteria is not explicitly addressed, although it is inferred that obtaining the VOC limits and transfer efficiency requires monitoring.

Stringency

- We believe Rule 11 51 fulfills RACT requirements because the VOC limits are generally more stringent than the CTG for, “Reduction for Volatile Organic Compound Emissions from Automobile Refinishing” and are equivalent to the limits set forth in CARB’s SCM for Automotive Coatings. Rule 1151 also places prohibitions and restrictions on hazardous air pollutants and toxic compounds that were previously not regulated by this rule.

SIP Relaxation

- T he VOC limits for the new categories , Pretreatment Coating, Multistage Coatings and Specialty Coatings , represent more stringent limits. In addition, some previously exempt VOC’s are now prohibited and carcinogenic
elements defined in Title 17 CCR §93112 are now not allowed as additives in the coatings. In addition, s olvents for preparation and cleaning are limited to 25 grams/liter VOC content. Although exemption s for automotive coatings sold in 0.5 fluid ounce containers and for motor vehicle manufacturing facilities w ere added, consistent with CARB’s SCM , they are likely to have limited emissions impact in Antelope Valley

. Therefore , we propose to determine that our approval of the submittal would comply with the CAA §110(l) and § 193 regarding SIP relaxation because the submitted SIP rule ensures VOC emissions equivalent to or greater than th o se of the ap plicable SIP rule for the area, AVAQMD Rule 1151 as amended in 1999.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– The following revisions are not currently the basis for rule disapproval, but are recommended for th e next time the rule is amended:
1. In Section (B), Definitions , please consider making the following changes:- 8

- a. In s ubsection (B) (19), in the Comparison of Coating Categories table,
f or Specialty Coatings please correct the descriptor in the Coating Categories 05/01/13 and after, per CARB’s comment, to read: “This generic category has been eliminated an d replaced with specific categories for the various coatings previous ly grouped together.”
b. In s ubsection (B ) ( 28), please clarify that Group II Exempt Compounds are VOC exempt compoun ds as listed in 40 CFR 51 (s ) ( 1) as indicated in CARB’s SCM.

c. For consistency , consider correcting the term Targeted HAP to Target
HAP in subsection (B) (5 7) to be in agreement with the definition in
40 CFR 63.11180.
d. For completeness, please refer to 40 CFR 51 (s) for the definition of Volatile Organic Compounds and Exempt Compounds in subsection (B ) ( 70).
2. In Section (C), we recommend the following changes:

a. In subsection (C ) ( 3 )( a), the definition of factor VOC LWc references Rule 1116 which actually refers to MDAQMD Rule 1116. Please revise this definition to “VOC Limit of this rule, less water and less Exempt Compounds, pursuant to Section (C )( 1).”
b. In subsection (C ) ( 3 )( b), consider having the Alternative Emission Control Plan comply with the provisio ns of subsection (C )( 1) as this encompasses all the VOC limit compliance guidelines.

c. For completeness, consider revising subsection (6)(a)(iv) to: “Any other Coating application which has been demonstrated to the satisfaction of the APCO to be capable of achieving a Transfer Efficiency equivalent to, or higher than, the application methods listed in subsections (C)(6)(a)(i), (C)(6)(a)(ii) and (C)(6)(a)(iii)
, above, but not less than 65 percent...” an d the NESHAP requires alternate- 9

- methods have a transfer efficiency greater than or equal to that of the HVLP spray. d. For consistency with subsec tion (D)(2) , consider changing reference to subsection (C)(3)(a) to (C)(3) in subsections (C)(8)(b)(i)a and (C)(8)(c)(i)a to include an alternate emission control plan as defined in subsection (C)(3)(b).
3. For consistency, please revise subsection (E )( 1 )( a ) ( v) to Target HAP per
recommendation 1. , c

. 4. To aid tracking and inspection, Bay Area Air Quality Management District (BAAQMD) Regulation 8, Rule 45, Motor Vehicle and Mobile E quip m ent Coating Operations , has a provisions that any person for whom mobile refinishing operation s are conducted at least five times in any one

- year period or for which 25 vehicles were refinished in any one

- year period shall keep record s indicating the following: t he name, address, phone number, retail tax license number, and val id District registration number of each mobile refinishing operator utilized; t he date(s) each mobile refinisher engaged in mobile refinishing operations; and t he number(s) of vehicles refinished by each mobile refinisher on the date(s). Please consider a similar provision to strengthen the enforceability of Rule 1151.
5. For consistency, p lease consider the following revisions to section (G):

a. In subsection (G)(2)(b), both SCAQMD rule 1151 and MDAQMD rule 1116 reference SCAQMD method 311

- 91, “ Determination of Weight Percent Elemental Metal in Coatings by Spectrographic Method ” , June 1, 1991 or revise the reference to method 318

- 95 to “ Determination of Weight Percent Elemental Metal in Coatings by X

- ray Diffraction ” , July 1, 1996.
b. The ASTM reference in subsection (G ) ( 2 ) ( d ) ( i) should be
corrected to D523

- 89(2008).- 10

- c. EPA method 25 refer ence in (G )( 2 )( g )( i) should include “40 CFR Part 60, Appendix A ”.
d. Correct the date and title of the ASTM test method referenced in (G)(2)(h)(i) to Method D6133

- 02 (2008) , “Standard Test Method for Acetone, p

- Chlorobenzotrifluoride, Methyl Acetate or t
- Butyl Acetate content of Solvent borne and Waterborne Paints, Coatings, Resins
and Raw M aterials by Direct Injection Into Gas Chromatograph.”
Remove the date , “(Feb ruary 2003)”
, as this is not a valid date for
this method.

e. In subsection (G )( 2 )( j )( i), p lease chang e the reference to section (G )( 2 )( 3) to (G )( 2 )( h )( i).
f. The reference in subsection (G )( 2 )( k )( i) is only a guideline. The test for equivalency, which should be referenced here, is SCAQMD Method “Spray Equipment Transfer Efficiency Test Procedure for Equipment User” (May 24, 1989).
g. Please provide test procedure (s) for Cadmium and Chromium
Hexavalent as re commended by the ATCM such as CARB Method 425, Determinatio n of Total Chromium and Hexavalent Chromium Emissions from Stationary Sources”, July 28, 1997

.

EPA ACTION

- Rule 11 51 fulfills the relevant CAA §110 and part D requirements. EPA staff recommends a full approval of Rule 11 51 pursuant to CAA §110(k ) ( 3 ) and §301(a)

.

ATTACHMENT S

- 1. AVAQMD Rule 11 51 , Motor Vehicle and Mobile Equipment Coating Operations , as a mend ed on J ul y 20 , 1997

.- 11

-

2. AV AQMD Rule 11 51 , Motor Vehicle and Mobile Equipment Coating Operations , as submitt ed on June 19, 2012

.

ADDITIONAL REFERENCES

– 1. EPA’s Control Technique Guidelines (CTG), “ Control Technique Guidelines for Emissions from Automobile Refinishing ” (EPA

- 45 0 / 3

- 88

- 0 09 ), Octo ber 19 88

. 2. Alternative Control Techniques (A CT) Document, “ Automotive Refinishing ” (EPA

- 45 3 / R

- 94

- 0 31 ), April 2004. 3. Air Toxic Control Measure (ATCM) (Title 17 CA ADC § 93112) for
Hexavalent Chromium and Cadmium Airborne Toxic Measure from Motor Vehicle and Mobile Equipment Coatings.
4. National Emission Standards for Hazardous Air Pollutants (NESHAP) ( 40 CFR Part 63, Subpart HHHHHH ) : Paint Stripping and Miscellaneous Surfa ce Coating Operations at Area Sources

. 5. CARB S uggested C ontrol M easure (SCM) f or “ Automotive Coatings ” as approved by the Board on October 20, 2005

. 6. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, ” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988

. 7. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, Augu st 21, 2001

.