Staff Report – Feather River AQMD

Rule 3.19 - Vehicle And Mobile Coating Operations

Rule3-19Rpt 6/1/98

Proposed Rule 3.19, Vehicle and Mobile Equipment Coating Operations

Date Of Release June 1, 1998

Date of Board Consideration: July 6, 1998

Executive Summary

The California Air resources Board and the Federal Environmental Protection Agency 

have promulgated health-based Ambient Air Quality Standards for photochemical 

oxidants, commonly referred to as ozone or smog. Volatile organic compounds are 

precursors to and react to form ozone in the atmosphere. The Feather River Air Quality 

Management District (FRAQMD) includes Yuba and Sutter Counties and is part of the 

Northern Sacramento Valley Air Basin (NSVAB) which has been designated moderate 

non-attainment for the health-based California Ambient Air Quality Standard for ozone. 

The California Clean Air Act (CCAA) of 1988 mandates that non-attainment area

development a plan to achieve attainment of the CCAA standards "at the earliest 

practical date.” The Northern Sacramento Valley Basin Coordinating Council, of which 

the FRAQMD is a member, developed an Air Quality Plan in response to this mandate in 

1991 (subsequently updated in 1994 and 1997). Potential emissions from automobile 

finish coatings were identified as a source of volatile organic compounds for which 

reasonable emissions controls exist. Rule 3.19, Vehicle And Mobile Coating Operations, 

is proposed to reduce the emissions of reactive organic compounds from vehicle and 

mobile coating operations. 

1.0 PURPOSE

The purpose of Proposed rule 3.19 is to reduce ambient ozone levels by controlling volatile 

organic compound (VOC) emissions into the atmosphere from the coatings and solvents used in 

automotive and mobile equipment refinishing. Ambient ozone is formed from the combination 

of reactive organic compounds (evaporative type emissions associated with petroleum based 

compound products) with oxides of nitrogen (combustion related compounds) in the presence of 

sunlight. The basic control strategy is to inventory the precursor compounds (i.e., reactive 

organic compounds, and oxides of nitrogen) and then seek cost-effective emission reductions 

from sources of these emissions. By reducing the precursors, the resultant ozone product is 

reduced, bringing the area into compliance with the health-based State and Federal ambient air 

quality standards.

2. BACKGROUND

The California Clean Air Act (CCAA) of 1988 mandates that a non-attainment areas 

development a plan to achieve attainment of the CCAA standards "at the earliest practical date." 

The Valley Air Basin (NSVAB) is considered to be a moderate non-attainment area for the 

California Ambient Air Quality Standard for ozone. The Northern Sacramento Valley developed 

an Air Quality Plan in response to this mandate in 1991 and updated this plan in 1994 and 1997.. 
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Rule 3.19 - Vehicle And Mobile Coating Operations

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Automobile finish coatings was included in the 1991 attainment plant for the Northern 

Sacramento Valley Air Basin and again included in the revised 1994 and 1997 attainment plans

in Table VI-1, "List of Feasible Measures for Stationary Sources" as a reactive organic gas 

(ROG) control measure. This measure was to be proposed and implemented by applicable 

Districts no later than July 1, 1996.

This draft rule is based on the “California Clean Air Act Guidance, Determination of Reasonable

Available Control Technology and Best Available Retrofit Control Technology (RACT, BART)

For Automotive Refinishing Operations” guideline document (dated January 8, 1991), from the

Draft “National Volatile Organic Compound Emission Standards for Consumer and Commercial 

Products”; Subpart E--National Volatile Organic Compound Emission Standards for Automobile

Refinish Coatings, and from rules other Districts have adopted for this category.

3.0 APPLICABILITY

This rule applies to any person who supplies, sells, offers for sale, applies, or specifies the use of 

coatings for vehicles, mobile equipment and their parts or components. 

4.0 STANDARDS

This rule does the following:

Contains a prohibition from manufacturing, soliciting, requiring for use, specifying, or 

selling, any coatings not meeting the limits of VOC content expressed in the rule.

Limits the VOC content of the coatings listed with respect to the type of coating and whether 

the application of the coating required a color match.

Includes an add on control equipment provision in the rule allows for the use of coatings that 

do not meet the requirements of the rule, provided that the overall control system efficiency is 

not less than 85 percent.

Includes housekeeping procedures and limits for the VOC content of surface preparation and 

cleanup materials.

Specifies the use of spray application equipment with a transfer efficiency of at least 65 

percent. 

Specifies the use of an enclosed gun cleaner or a low emissions spray gun cleaner for spray 

equipment cleaning. 

Requires that coating of an entire vehicle be performed in a spray booth.
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Rule 3.19 - Vehicle And Mobile Coating Operations

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5.0 EXEMPTIONS

Coatings in hand-held non-refillable aerosol containers and non-aerosol containers with a 

capacity of 16 fluid ounces or less are exempt from the rule.

The application of logos, letters, numbers, and graphics to a painted surface is exempt from the 

rule.

Any coating operation of a vehicle or mobile equipment by a resident of a one or two family 

dwelling is exempt provided the resident is the registered owner, is not being conducted as a 

business, limited to two vehicles per year, and does not cause a public nuisance. 

Exemption from the spray booth and prep station requirement is allowed with prior approval 

from the APCO for vehicles which, due to the shape or size, cannot reasonably be contained in 

any available substitute spray booth.

Exemption from the spray booth and prep station requirement is allowed for touch-up and repair, 

or spot priming operations which do not exceed nine (9) square feet per vehicle.

Exemption from the spray booth and prep station requirement is allowed for any weld-thru 

primer.

Also proposed is a limited exemption for non-commercial operations, including agricultural

operations and construction vehicles. 

6.0 RECORDS AND TEST METHODS

The rule requires that a list of currently used coatings and surface preparation and cleanup 

materials (e.g., solvents) be maintained along with Material Safety Data Sheets (MSDS).

The rule requires that daily records be maintained with the coating identification, mix ratios, 

quantity of each coating applied and whether a color match was required.

The rule requires that manufacturers specification sheets for solvent used for substrate surface 

cleaning and application equipment cleanup be available for review as well as daily records kept 

which identify each solvent and its use, the VOC content of the solvent, and the volume used.

This rule requires that records be maintained for a minimum of two years from the date of each 

entry and be available to District personnel upon request.

The rule contains appropriate test methods to determine compliance with the rule requirements 

for VOC limits and emission control equipment.
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7.0 AVAILABILITY OF COATINGS AND SOLVENTS

Manufacturers have already reformulated and field-tested surface coatings meeting the 

requirements of this proposed rule. These coatings are currently available on the market and 

have been in use in many counties in California for several years. In addition, the limits 

proposed are those that have been identified in the draft “National Volatile Organic Compound 

Emission Standards for Consumer and Commercial Products”; Subpart E--National Volatile 

Organic Compound Emission Standards for Automobile Refinish Coatings. These limits are 

proposed as national limits and have been researched, and workshopped with paint manufacturers

throughout the United States. The VOC limit for solvents in this proposed rule will not 

adversely limit the types of solvents currently utilized.

8.0 CONTROL EFFICIENCY

Table VI-1, "List of Feasible Measures for Stationary Sources" in the 1994 attainment plan 

update estimates that an automobile finish coatings measure would provide a 25 percent control 

efficiency.

9.0 COST IMPACTS

The implementation of the rule will require some auto body shop businesses to purchase new 

equipment to stay competitive. Most of these purchases are a one-time purchase and therefore 

should be amortized over a ten-year lifetime. This equipment may include, but is not limited to, 

paint booths, heat lamps, fans or room heaters, additional booth insulation, HVLP spray guns and 

tips, and/or enclosed gun cleaners. 

The rule may necessitate operators to install heat lamps, fans or room heaters to meet the 

compliance deadline for the primers/surfacers.

The necessity of a booth is required for all paint application facilities that coat surfaces greater 

than 9 square feet. This requirement for a booth is also currently mandated by the Uniform Fire 

Code. Therefore this expense is not expected to be a new cost. 

The implementation of this rule will require some shops to purchase HVLP Spray guns. 

Currently the industry standard has been to use these types of guns because of the savings in 

paint costs due to the higher transfer efficiencies. However, some shops have not converted all 

guns to HVLP's.

The implementation of this rule will require some shops to purchase an enclosed gun cleaner. 

Currently most shops are equipped with these gun cleaners to ease in gun cleanup.
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Additionally, extra costs may be incurred while users of the new coatings become familiar with 

their application. More care may be required for training on how to mix, apply, and cure the 

newer coating systems. However, these costs are expected to be minimal and would have 

occurred anyway with the adoption of the national standards.

Some facilities may not be affected by this rule. For example, some facilities are currently using 

low-VOC coatings and applying those coatings using HVLP guns in heated booths and clean 

their guns with enclosed gun cleaners. 

Activity Capital Costs

Spray Booths: $60,000 - $100,000

Spray Guns (HVLP): Typical cost $450-$500 but can go as high as $1,200

Spray Gun Tips: $200 per tip

Enclosed Gun Cleaner: $1000 -$2000

Portable Heat Lamp: $1500 per infrared lamp

Low VOC Coatings: The cost differential between these and conventional coatings 

may be recuperated from material savings due to HVLP guns

10. COST EFFECTIVENESS

Table VI-2 in the 1994 attainment plan lists the automobile finishes coatings control measure at 

$2,000 per ton as being cost effective. The ARB RACT/BARCT guideline document states that 

the cost effectiveness for implementing RACT/BARCT is $2-$2.25 per pound of VOC reduced 

($4,000 - $4,500 per ton). However, this rule does not implement all BARCT implementation 

measures and VOC limits. It is expected that the actual cost effectiveness will vary since many 

facilities currently have the equipment on hand or will only need to purchase a portable heat 

lamp.

For example, if a facility purchases two heat lamps, an enclosed gun cleaner, three HVLP Spray 

guns and tips, then costs are:

(2) Heat Lamps: $3,000

(1) Enclosed Gun Cleaner: $1,500

(3) HVLP Spray Guns & Tips: $2,100

----------------------------------------------------

Total: $6,600

Assuming a 25% emissions decrease from the implementation of the rule then: 72.5 Tons/year x 

.25 reduction = 18.125 tons/year of VOC emission decrease that could be expected in the 

NSVAB (see table below). 
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If 1/4 of the sources are required to purchase all of the above equipment, then the cost per ton 

of VOC reduced is 115 sources/ 4 = 29 sources. 29 sources x $6,600 = $191,400 if 18.125 tons 

of VOC reduced, then = $10,560/ton reduced. 

If 1/4 of the sources are required to purchase only the heat lamps, then the cost per ton of VOC

reduced is: 29 sources x $3,000 = $87,000 if 18.125 tons of VOC reduced, then = $4,800/ton 

reduced. 

Please note, these estimates are not amortized and therefore are over-estimates when compared to 

a 10 year operation lifetime of the equipment.

It is not expected that any facility will choose to use add-on control equipment in order to utilize 

coatings not meeting the VOC limits of the rule.

11.0 EMISSIONS INVENTORY

A survey of the number of auto body refinish shops and other companies that refinish mobile 

equipment is included below by District. The actual number of facilities and emissions are 

expected to be greater due to the lack of facilities currently in the permit system and the unknown 

number sources that refinish mobile equipment:

County: No of Permitted 

Facilities

Total VOC Emissions (Tons)

Butte County AQMD 35 35.00 (1) 

Colusa County APCD 8 4.11 (2)

Feather River AQMD 2 3.00 (3)

Glenn County APCD 0 unknown (4)

Shasta County AQMD 61 17.46 (5)

Tehama County APCD 9 12.93 (1)

Total: 115 72.5

(1) From auto body facilities only

(2) All known sources

(3) Emissions based on two permitted sources expect 16 more will obtain a permit

(4) No sources permitted, no emissions data available

(5) 1994 emissions inventory. Emissions from insignificant sources (sources less than 0.5 

tons) are not included. Emission total is from 29 of the 61 known sources.