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, 2012
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Agency: Antelope Valley Air Quality Management District 

(AVAQMD)

SIP Approved Rule: Rule 1151- Motor Vehicle and Mobile Equipment 

Coating Operations

Adopted – July 8, 1988

Amended – July 20, 1999

Submitted– October 29, 1999

EPA Approval – April 10, 2000 (65 FR 18901)

Subject of this TSD: Rule 1151 - Motor Vehicle and Mobile Equipment 

Coating Operations

Amended – June 19, 2012

Submitted – September 21, 2012

RULE SUMMARY - AVAQMD Rule 1151, Motor Vehicle and Mobile Equipment 

Coating Operations, is a rule designed to limit volatile organic compound (VOC) 

emissions from the coatings and solvents associated with the refinishing of motor 

vehicles, mobile equipment and their associated parts and components. Section 

(B), Definitions, includes 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 coatings, promoters and sealers on and after 5/13/2013, Table 2 

that lists VOC limitations for coatings, primers 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 exempt VOC 

compounds and carcinogenic materials. Section (D), Exemptions, lists types of 

coating and coating operations exempt from the VOC limits, including assembly line 
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coatings, coatings sold outside the district, coatings sold in small quantities, 

coatings applied for educational purposes and coatings that are regulated by 

AVAQMD’s Rule 442. Section (E), Administrative Requirements, covers 

manufacturers’ compliance procedures and labeling and Section (F), Recordkeeping 

Requirements, indicate requirements 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 subsection and suppliers and appliers, for which the rule is 

applicable, were added to the Applicability subsection.

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 Coatings1in 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 coating meets the definition of multiple categories 

was added.

c. Alternative 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
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d. Select exempt VOC’s are prohibited from manufacture, sale and 

distribution.

e. The carcinogenic materials previously restricted from manufacture are 

further defined by a California Public Health code2. 

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. Solvents for surface preparation and cleaning operations in this rule, 

work practices for the handling and storage of solvents and the 

establishment 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 function.

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.
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Hazardous Air Pollutants (NESHAP): Paint Stripping and Miscellaneous 

Surface Coating Operations at Area Sources3.

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, acetone 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) requirement for enforceability.

2. Stringency – EPA’s Control Technique Guidelines (CTG) for, “Reduction for 

Volatile Organic Compound Emissions from Automobile Refinishing” (EPA450/3-88-009), dated October 1988, Alternate Control Techniques (ACT) 

Document: “Automotive Refinishing” (EPA-453/R-94-031) dated April 1994, 

Maximum Achievable Control Technology (MACT) “NESHAP Standards for 

Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating 

Operations at Area Sources” (40 CFR 63 Subpart HHHHHH), CARB’s Air 

Toxic Control Measure (ACTM) 17 CA ADC § 93112, “Hexavalent Chromium 

and Cadmium Airborne Toxic Measure – Motor Vehicle and Mobile Equipment 

Coatings”, CARB’s SCM for Automotive Coatings (approved by the board on 

October, 2005) and other state 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
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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 nonattainment 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 implemented. 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 limits have compliance dates and there is a comparison table of 

previous and current coating categories that assures 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. Additionally, 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 factors 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. 
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Monitoring criteria is not explicitly addressed, although it is inferred that obtaining the 

VOC limits and transfer efficiency requires monitoring. 

Stringency - We believe Rule 1151 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 - The 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, solvents for preparation and cleaning are limited to 25 

grams/liter VOC content. 

Although exemptions for automotive coatings sold in 0.5 fluid ounce containers and 

for motor vehicle manufacturing facilities were 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 those of the applicable 

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 the next time the rule is amended:

1. In Section (B), Definitions, please consider making the following changes:
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a. In subsection (B)(19), in the Comparison of Coating Categories table, 

for 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 and replaced with specific 

categories for the various coatings previously grouped together.”

b. In subsection (B)(28), please clarify that Group II Exempt 

Compounds are VOC exempt compounds 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)(57) 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 VOCLWc 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 provisions 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...” and the NESHAP requires alternate 
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methods have a transfer efficiency greater than or equal to that of the 

HVLP spray.

d. For consistency with subsection (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 Equipment 

Coating Operations, has a provisions that any person for whom mobile 

refinishing operations 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 records indicating the following: the name, address, phone number, 

retail tax license number, and valid District registration number of each 

mobile refinishing operator utilized; the date(s) each mobile refinisher 

engaged in mobile refinishing operations; and the 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, please 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).
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c. EPA method 25 reference 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 Materials by Direct Injection Into Gas Chromatograph.”

Remove the date, “(February 2003)”, as this is not a valid date for 

this method.

e. In subsection (G)(2)(j)(i), please change 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 recommended by the ATCM such as CARB Method 

425, Determination of Total Chromium and Hexavalent Chromium 

Emissions from Stationary Sources”, July 28, 1997.

EPA ACTION - Rule 1151 fulfills the relevant CAA §110 and part D requirements. 

EPA staff recommends a full approval of Rule 1151 pursuant to CAA §110(k) (3) 

and §301(a).

ATTACHMENTS -

1. AVAQMD Rule 1151, Motor Vehicle and Mobile Equipment Coating 

Operations, as amended on July 20, 1997.
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2. AVAQMD Rule 1151, Motor Vehicle and Mobile Equipment Coating 

Operations, as submitted on June 19, 2012. 

ADDITIONAL REFERENCES –

1. EPA’s Control Technique Guidelines (CTG), “Control Technique Guidelines 

for Emissions from Automobile Refinishing” (EPA-450/3-88-009), October

1988.

2. Alternative Control Techniques (ACT) Document, “Automotive Refinishing”

(EPA-453/R-94-031), 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 Surface 

Coating Operations at Area Sources.

5. CARB Suggested Control Measure (SCM) for “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, August 21, 2001.