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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Sacramento Metropolitan Air Quality Management District, Rule 459, Automotive, 

Mobile Equipment and Associated Parts and Components Coating 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)

SIP Approved Rule: Rule 459 – Automotive, Truck and Heavy 

Equipment Refinishing Operations

Adopted – 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

Amended – August 25, 2011

Submitted - February 23, 2012

Background – The SMAQMD is designated as a “severe” nonattainment area for the 

Federal 8-hour ozone standard. As a result, Clean Air Act (CAA) section 182(b)(2)

requires all “reasonable available control technology” (RACT) be applied to sources of 

volatile organic compound (VOC) emissions covered by an EPA control technique 

guideline (CTG). Among other things, this amendment to Rule 459 is intended to satisfy 

the RACT requirement associated with the CTG for coating motor vehicles and the CTG 

for miscellaneous 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 Rule 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 Metal and Plastic Parts Coatings”, (metal parts CTG,

September 2008) and EPA’s “Control Techniques Guidelines for Automobile and LightDuty Truck Assembly Coatings” (auto-coating CTG, September 2008). This proposed 

amendment is also intended to satisfy the CAA requirement to implement RACT for 

these coatings and materials. 

EPA Evaluation – The following criteria and guidance documents were used to 

evaluate the submitted rule.
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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 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 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).

Rule Evaluation – The monitoring, recordkeeping, reporting and other requirements 

ensure that Rule 459 can be adequately enforced. 

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

the SIP as RACT. The VOC limits are either equal or lower and other requirements of 

this rule are as stringent as those described in the SCM, metal parts CTG and autocoating CTG. As a result, we conclude that this rule fulfills the RACT 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 –We have identified no deficiencies with Rule 459 sufficient for EPA 

to propose less than full approval.

Recommended for the Next Rule Revision – The following revisions are 

recommended 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 Plastic 
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Parts and Products, 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 Air Quality Management 

District, Rule 1116, August 2010.

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

4. “Guidance Document for Correcting Common 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 and Plastic Parts 

Coating,” EPA (EPA-453/R-08-003, September 2008).

7. “Motor Vehicle and Mobile Equipment Non-assembly Line Coating Operations”, 

South Coast Air Quality Management District, Rule 1151, December 2005.

8. “Motor Vehicle and Mobile Equipment Coating Operations”, San Joaquin Valley 

Air Quality Management District”, Rule 4612, October 2010.