SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis September 17, 2009 

B-1 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

APPENDIX B 

Rule Consistency Analysis 

For 

Proposed Amendments to 

Rule 4602 

September 17, 2009 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis September 17, 2009 

B-2 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis September 17, 2009 

B-3 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

APPENDIX B 

Rule Consistency Analysis 

I. REQUIREMENTS OF ANALYSIS 

Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting, 

amending, or repealing a rule or regulation, the District is required to perform a written 

analysis that identifies and compares the air pollution control elements of the rule or 

regulation with corresponding elements of existing or proposed District and United 

States Environmental Protection Agency (EPA) rules, regulations, and guidelines that 

apply to the same source category. The elements that were analyzed are emission 

standards, monitoring and testing, and recordkeeping and reporting requirements. 

II. RULE CONSISTENCY ANALYSIS 

A. District Rules 

Facilities could be subject to other District rules including: 

 Rule 2201 New and Modified Stationary Source Review Rule 

 Rule 4001 New Source Performance Standards 

 Rule 4002 National Emissions Standards for Hazardous Air Pollutants 

 Rule 4603 Surface Coating of Metal Parts and Products 

 Rule 4612 Motor Vehicle and Mobile Equipment Coating Operations 

 Rule 4653 Adhesives 

 Rule 4661 Organic Solvents 

 Rule 4663 Organic Solvent Cleaning, Storage, and Disposal 

The above-listed rules are not in conflict with, nor are they inconsistent with the 

requirements of Proposed Rule 4602. 

B. Federal EPA Rules and Regulations 

1. Federal Control Techniques Guideline (CTG) 

1977 CTG for Control of Volatile Organic Emissions from Existing Stationary Sources 

Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty 

Trucks (EPA-450/2-77-008). The 1977 CTG and subsequent implementation guidance 

provided RACT recommendations for controlling VOC emissions from automobile and 

light-duty truck assembly surface coating operations. These recommendations are 

summarized in Table 1. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis September 17, 2009 

B-4 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

Table 1. 1977 CTG Recommended VOC Emission Limits of Automobile and Light- 

 Duty Truck Surface Coatings. 

Electrodeposition primer operation 

0.14 kg VOC/liter (1.2 lb/gal) of coating, 

excluding water and exempt compounds, or 

0.17 kg VOC/liter (1.4 lb VOC/gallon) of 

coating solids deposited 

Primer-Surfacer (guidecoat) 

operation 

1.8 kg VOC/liter (15.1 lb VOC/gallon) of 

coating solids deposited on a daily average 

basis as determined by following the 

procedures in the Automobile Topcoat 

Protocol 

Topcoat operation 

1.8 kg VOC/liter (15.1 lb VOC/gallon) of 

coating solids deposited on a daily average 

basis as determined by following the 

procedures in the Automobile Topcoat 

Protocol 

Final repair operation 0.58 kg VOC/liter (4.8 lb/gal) of coating, 

excluding water and exempt compounsd 

2. Alternative Control Technology (ACT) 

There is no EPA ACT for automobile and light-duty truck assembly coatings. 

3. Federal New Source Performance Standards (NSPS) 

40 CFR part 60 subpart MM (1980) The NSPS established the emission limits 

calculated on a monthly basis for each prime coat operation, guide coat (primersurfacer) operation, and topcoat operation located in an automobile or light-duty truck 

assembly plant constructed, reconstructed, or modified after October 5, 1979. The 

NSPS does not apply to plastic body component coating operations or to all-plastic 

automobile or light-duty truck bodies coated on separate coating lines. The VOC 

emission limit for prime coat operations depends on the solids turnover ration (RT). The 

solids turnover ratio is the ratio of total volume of coating solids added to the EDP 

system in a calendar month to the total volumetric design capacity of the EDP system. 

The NSPS limits and the 1977 CTG recommendations for primer-surfacer and topcoat 

cannot be directly compared because of differences in the compliance period and how 

transfer efficiency is considered. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis September 17, 2009 

B-5 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

Table 2. 1980 NSPS VOC Emission Limits for Automobile and Light-duty Truck 

 Surface Coatings 

Prime coat Operations 

(Non-EDP) 0.17 kg VOC/liter (1.42 lb/gal) coating solids applied 

When solids 

turnover ration 

(RT) > 0.16: 

When 0.040< RT

<0.160: When RT <0.040: 

Prime coat Operations 

(EDP) 

0.17 kg VOC/liter 

(1.42 lb/gal) 

coating solids 

applied 

0.17x350 0.160- RT 

Kg VOC/liter 

(0.17x350 0.160- RT

x8.34 lb/gal) 

coating solids 

applied 

No VOC emission 

limit 

Guide coat Operations 

(including the guide 

coat application, flashoff area, and oven) 1.40 kg VOC/liter (11.7 lb/gal) coating solids applied 

Topcoat Operations 

(including topcoat 

application, flash-off 

area, and oven) 1.47 kg VOC/liter (12.3 lb/gal) coating solids applied 

4. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Performance Standards (MACTs) 

40 CFR part 63 Subpart IIII (2004), National Emission Standards for Hazardous Air 

Pollutants; Surface Coating of Automobile and Light-Duty Trucks. The NESHAP 

covers all equipment used to apply coating to new automobile or light-duty truck bodies 

or body parts and to dry or cure the coatings after application; all storage containers and 

mixing vessels in which vehicle body coatings, thinners, and cleaning materials are 

stored and mixed; all manual and automated equipment and containers used for 

conveying vehicle body coatings, thinners, and cleaning materials; and all storage 

containers and all manual and automated equipment and containers used to convey 

waste materials generated by an automobile and light-duty truck assembly coating 

operation. 

The 2004 NESHAP for automobile and light-duty truck assembly coating imposed 

organic HAP emission limitations calculated on a monthly basis for existing sources. 

More stringent limits apply to new sources. The NESHAP also sets emission limits for 

coatings not included in the CTG or NSPS, including glass bonding primer, glass 

bonding adhesive, and some coatings and thinners. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis September 17, 2009 

B-6 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

Table 3. 2004 NESHAP HAP Emission Limits for Automobile and Light-Duty 

 Truck Surface Coatings. 

0.060 kg organic HAP/liter of coating solids 

deposited (0.50 lb/gal) for new or 

reconstructed affected sources 

Combined primer-surfacer, topcoat, final 

repair, glass bonding primer, and glass 

bonding adhesive operation plus all 

coatings and thinners, except for deadener 

materials and for adhesive and sealer 

materials that are not components of glass 

bonding systems, used in coating 

operations added to the affected source. 

0.132 kg organic HAP/liter of coating solids 

deposited (1.10 lb/gal) for existing affected 

sources 

0.036 kg organic HAP/liter of coating solids 

deposited (0.30 lb/gal) for new or 

reconstructed affected sources 

Combined electrodeposition primer, primersurfacer, topcoat, final repair, glass 

bonding primer, and glass bonding 

adhesive operation plus all coatings and 

thinners, except for deadener materials 

and for adhesive and sealer materials that 

are not components of glass bonding 

systems, used in coating operations added 

to the affected source 

0.072 kg organic HAP/liter of coating solids 

deposited (0.60 lb/gal) for existing affected 

sources 

5. EPA Policy on Recordkeeping 

The recordkeeping requirement in Rule 4602 is consistent with EPA’s policy to keep 

and maintain records for at least five years. 

III. CONCLUSION 

Based on the above analysis, District staff found that the proposed amendments to Rule 

4602 would not conflict with federal rules, regulations, or policies covering similar 

stationary sources.