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UNI TED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

S acramento Metropolitan A ir Quality Management District, Rule 459

, Automotive, Mobile Equipment and Associated Parts and Components C oating Operations

Prepared by: Sally Grady Reviewed by: Andrew Steckel

April 2012

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Rule Identification

Agency: Sacramento Metropolitan Air Quality Management District (SMAQMD)

S IP Approved Rule: Rule 459

– Automotive

, Truck and Heavy Equipment Refinishing Operations

A dopted

– December 7, 1995

Submitted

– May 18, 1998 EPA Approved

– October 28, 1998 (63 FR 63410)

Subject of this TSD: Rule 459

– Automotive, Mobile Equipment and Associated Parts and Components Coating Operations

A mend ed

– August 25, 2011

Submitted

- February 23 , 2012

Background

– The S MAQMD is designated as a “severe” nonattainment area f or the

Federal 8

- hour ozone standard. As a result, Clean Air Act ( CAA ) section 182( b )(2) requires all “reasonable available control technolo g y” (RACT) be applied to sources of

volatile organic compound (VOC) emissions covered by a n EPA control technique guideline (CTG). Am ong other things, this amendment to Rule 459 is intended to satisfy the RACT requirement associated with the CTG for c oating motor vehicles and the CTG

for miscellane ous and plastic parts as it regards to motor vehicles

.

RULE SUMMARY

– Rule 459 was first adopted on December 7, 1995. The rule applies to coating, coating removal (stripping), surface preparation and cleanup operations for automotive, truck or heavy equipment finishing or refinishing and the regulation or sale of coatings within the District. The recent revisions amend R ule 459 to incorporate the requirements of the California Air Resources Board’s ( CARB) “Suggested Control Measure for Automotive Coatings” (SCM

, October 2005 )

, EPA’s “Control Techniques

Guidelines for Miscellaneous M etal a nd Plastic Parts Coatings”, (metal parts CTG

, September 2008) and EPA’s “Control Techniques Guidelines for Automobi le and Light

Duty Truck Assembly Coatings” (auto

- coating CTG, September 2008) . Th is proposed

amendment is also intended to satisfy the CAA requirement to implemen t RACT for these coatings and materials.

EPA Evaluation

– The following criteria and guid ance documents were used to

e valuate the submitted rule.3

Enforceability

- The Bluebook

, “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations ” ( EPA, May 25, 1988 )

, and t he Little Bluebook

“ Guidance Document for C orrecting Common VOC and 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

.

Stringency

– CARB’s 2005 SCM, EPA’s metal parts CTG, EPA’s auto

- coating CTG and

other state and local rules for this category were used to help evaluate the RACT requirements of CAA §182(b)(2) and §182(f).

SIP Relaxation

– We have evaluated this proposed SIP revision to determine whether it would interfere with any applicable requirement concern ing 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 effe ct before November 15,1990 (CAA §193).

Rule Evaluation

– The monitoring, recordkeeping, reporting and other requirements

ensure that R ule 459 can be adequately enforced.

The submitted rule is equal or more stringent than the version previously approved into

the SIP as RACT

. T he VOC limits are either equal or low er and other requirements of this rule are as stringent as those described in the SCM, metal parts CTG and auto

coating CTG. A s a result, we conclude that this rule fulfills the RAC T requirements of

CAA § 182(b)(2).

This new version of Rule 459 has lowered the VOC limits for solvents and several coatings. We do not find anything in this submitted rule that is less stringent than the version previously approved

. As a result, we conclude this revision strengthens the SIP and complies with § 110) ( a )(1) and § 193

.

Rule Deficiencies

–

W e have identified no deficiencies with Rule 459 sufficient for EPA to propose less than full approval.

Recommended for the Next Rule Revision

– The following revision s are

r ecommended for the next time the rule is amended:

1. Section 404, “Any person using emissions control equipment

... shall also specify which daily records must be kept to document these operations and maintenance procedures.” We suggest you consider using the wording from CARB’s SCM to specify some of the parameters to be included , such as “ “Key system operating
parameters necessary to ensure or document compliance, with emission control
systems including, but not limited to, temperatures, pressure drops and air flow

rates

. 2. Please adopt and submit Rule 468 “Surface Coating of Miscellaneous Plastic4

Parts and P roducts, Business Machine and Transportation Plastic Parts and Pleasure Craft”, as soon as possible in order to fulfill the RACT requirement

associated with the metal parts CTG that are not related to automobile coating.

EPA Action

– The submitted Rule 459 strengthens the SIP. The rule fulfills the relevant

CAA §110 and part D requirements. EPA staff recommends a full approval of Rule 459 pursuant to CAA §110 and §301(a).

References

1. “ Control Techniques Guidelines for Automobile and Light

- Duty Truck Assembly Coatings

, ” EPA (EPA

- 453/R

- 08

- 006, September 2008)

. 2. “Automotive Refinishing Operations”, Mojave Desert Ai r Quality Management
District, Rule 1116, August 2010

. 3. “ Suggested Control Measure for Automotive Coatings ”, CARB, 2005

. 4. “Guidance Document for Correcting Commo n VOC & Other Rule Deficiencies ” (A.K.A., The Little Bluebook)

, EPA Region 9, August 21, 2001

. 5. “ Issues Relating to VOC Regulation Cut

- points, Deficiencies and Deviations “ (A.K. A., The Bluebook)

, EPA, 1988

. 6. “ Control Techniques Guidelines for Miscellaneous Metal a nd Plastic Parts Coating,” EPA (EPA

- 453/R

- 08

- 0 03, September 2008)

. 7. “Motor V ehicle and Mobile Equipment Non

- assembly Line Coating Operations”,

South Coast A ir Quality Management District, Rule 1151, December 2005

. 8. “Motor Vehicle and Mobile Equipment Coating Operations”, San Joaquin Valley Air Quality Management District”, Rule 461 2, October 2010.