UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Feather River Air Quality Management District Rule 3.19

Vehicle and Mobile Equipment Coating Operations

Prepared by Arnold Lazarus

Reviewed by: Andrew Steckel

March 2015
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RULE IDENTIFICATION

Agency: Feather River Air Quality Management District (FRAQMD)

SIP Approved Rule: There are no versions of FRAQMD Rule 3.19 which have

been SIP approved.

Subject of this TSD: Rule 3.19 - Vehicle and Mobile Equipment Coating 

Operations

Adopted - August 6, 1998

Amended - August 1, 2011

Submitted - February 10, 2014

BACKGROUND - FRAQMD Rule 3.19 is a new rule to the federally approved State 

Implementation Plan (SIP) that was adopted by FRAQMD to establish limits on the 

emission of volatile organic compounds (VOC) from vehicle and mobile equipment 

coating operations (VMECO). The southern portion of Sutter County has been 

classified for 8-hour Ozone as Severe Nonattainment, Sutter Buttes (>2000 ft) has 

been classified as Nonattainment, and the balance of FRAQMD has been classified as 

Unclassified/Attainment.1

Rule 3.19 would be obligated by the Clean Air Act (CAA) §182 (b) and (d) to 

implement reasonably available control technology (RACT) if there were any EPA 

Control Techniques Guidelines (CTG) for VMECO or any major sources ( >25 tons per 

year of VOC) relevant to Rule 3.19 within the non-attainment area in FRAQMD. 

However, according to the FRAQMD, “The District does not have any major sources

located within the nonattainment area, and does not anticipate any major sources or

sources subject to a CTG in the future.”2 On August 18, 2014, FRAQMD submitted a 

RACT SIP Analysis and Negative Declaration pursuant to sections 182(b)(2) and (f) of 

the CAA for the south Sutter County Portion of the Sacramento Nonattainment Area for 

the 2008 8-hour Ozone National Ambient Air Quality Standard to CARB. CARB 

subsequently submitted the RACT SIP to the EPA on September 29, 2014. In the 

RACT SIP Analysis and Negative Declaration, FRAQMD declared that Holt of 

California, with the largest potential to emit for this category, was permitted up to 7.85 

tons per year in the district, well below the 25 ton/year threshold. 

According to the District’s staff report for Rule 3.19, “The District is aware of the 

Suggested Control Measures (SCM) proposed by CARB for Automotive Coatings. This 

SCM proposes to reduce the VOC limits of various automotive coatings listed in District 

Rule 3.19. However the District will not implement the SCM at this time. The District is 

 1 40 CFR Ch. I §81.305 (7-1-14 Edition)

2 FRAQMD “Reasonably Available Control Technology Analysis and Negative Declaration”, July 3, 2014. 

P2.
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planning to review the SCM requirements within the next few years and determine if it 

will be a cost-effective measure for Yuba and Sutter Counties.”3

The Rule is consistent with the National Volatile Organic Compound Emission 

Standards (40 CFR Part 59) Subpart B-National Volatile Organic Compound Emission 

Standards for Automotive Refinish Coatings (NVOCESARC).

4

RULE SUMMARY -

Rule 3.19 establishes VOC content limits and workplace standards for VMECO. It also 

contains pertinent definitions, exemptions, recordkeeping, reporting, and monitoring 

requirements.

EVALUATION CRITERIA -

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 help evaluate compliance with the 

CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency – The Code of Federal Regulations (CFR) Title 40 Subpart B National 

Volatile Organic Compound Emission Standards for Automobile Refinish Coatings 

§59.102 Standards table 1 (40 CFR 59.102, table 1), the SCM proposed by CARB 

for Automotive Coatings and other state and local rules for this category were 

used to help evaluate the RACT requirements of CAA §182(b) and §182(d). 

3. SIP Relaxation - CAA §110(l) prohibits EPA from approving any SIP revision that 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the 

CAA. In addition, CAA §193 prohibits the modification of any SIP-approved control 

requirement in effect before November 15, 1990, in a nonattainment area.

EPA EVALUATION -

1. The rule requirements and applicability are clear, and the monitoring, 

recordkeeping, reporting and other provisions sufficiently ensure that affected 

sources and regulators can evaluate and determine compliance with Rule 3.19

consistently. 

2. The submitted rule is as stringent as NVOCESARC but not as stringent as 

CARB’s SCM for Automotive Coatings, South Coast Air Quality Management 

District’s (SCAQMD) Rule 1151, San Joaquin Valley Air Pollution Control District’s 

 3 FRAQMD, “Final Staff Report Rule 3.19,” June 6, 2011, p6-7. 4 National Volatile Organic Compound Emission Standards, 40 CFR § 59.102, Subpart B, Table 1,VOC 

Content Limits for Automobile Refinish Coatings.
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(SJVAPCD) Rule 4612 or Ventura County Air Pollution Control District’s 

(VCAPCD) Rule 74.18. Table 1 below compares the VOC content limits in 

FRAQMD Rule 3.19, the Federal Standards, CARB’s SCM and these other 

example local District Rules that are SIP approved.

Table 1

VOC Content Limits in grams/liter (g/l)

Coating Category

FRAQMD

3.19

Group I/II NVOCESARC SCM SCAQMD

1151

SJVAPCD 

4612

VCAPCD 

74.18

Pretreatment Wash 

Primers 780/780 780 660 660 660 660

Primers/ Primer 

surfacers 340/340 580 250 250 250 250

Primer Sealers 420/340 550 250 250 250 250

Single/Two Stage 

Topcoat 600/420 600 340 340 340

Topcoats of more than 

two stages 600/420 630

Multi-colored Topcoats 680 680 680 680 680

Specialty coatings 840 840

Extreme Performance 750

Camouflage 420

Clear Coating 250 250 250 250

Color Coating 420 420 420 420

Underbody Coating 430 430 430 430

Adhesion Promoter 540 540 540 540

Temporary Protective 

Coating 60 60 60 60

Truck Bed Liner 

Coating 310 310 310 310

Any other coating type 250 250 250 250

Uniform Finish Coating 540 540 540 540
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As a result, we believe Rule 3.19 does not implement RACT-level requirements. 

However, as discussed above, Rule 3.19 does not have to satisfy RACT because 

there are no CTGs that apply to the rule and no major sources of emission in the 

non-attainment area that the rule addresses.

3. We propose to determine that our approval of the submittal would comply with 

CAA §§110(l) and 193 because the emissions reductions from FRAQMD Rule 

3.19 are included in baseline emissions estimates in the Sacramento Regional 8-

Hour Ozone Attainment and Reasonable Further Progress Plan, approved by the 

EPA at 80 FR 4795 (January 29, 2015), and the emission limits in the submitted 

rule are more stringent than having no pertinent rule in the SIP for FRAQMD.

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. Please adopt CARB’s SCM standards which have been demonstrated to be 

reasonably available in many areas.

2. Discontinue the Group 1 and Group 2 Categories consistent with CARB’s SCM 

standards.

3. Consistent with CAA Title V and the federal statute of limitations, we recommend 

that Section (4) (g) require that records be maintained for five instead of two 

years.

4. In “Test Methods E.2,” Acid Content, please change to the following: 

Measurement of acid content shall be determined by using American Standards 

for Testing and Materials (ASTM) D1613-03.

5. In “Test Methods E.3,” please change name from SCAQMD Method 318 to 

“SCAQMD Method SC 318-95.”

6. Consistent with National Emission Standards for Hazardous Air Pollutants, Paint 

Stripping and Miscellaneous Surface Coating Operations (Subpart HHHHHH) , 

(40 CFR §63.11173(e)(1)) we recommend adding a requirement that all painters 

must be trained and certified after training.

EPA ACTION

The submitted Rule 3.19 strengthens the SIP by imposing new requirements.. The rule 

largely fulfils the relevant CAA §110 and part D requirements. Therefore, EPA staff 

recommends a full approval pursuant to CAA §110(k)(3) and §301(a).

REFERENCES -

1. FRAQMD Rule 3.19, Vehicle and Mobile Equipment Coating Operations, as 

amended August 1, 2011 and submitted to the EPA on February 10, 2014. 

2. FRAQMD, “Final Staff Report Rule 3.19,” June 6, 2011, p6-7.
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3. FRAQMD “Reasonably Available Control Technology Analysis and Negative 

Declaration”, July 3, 2014.

4. SCAQMD Rule 1151, Motor Vehicle and Motor Equipment Non-Assembly Line 

Coating Operations, amended December 2, 2005, and approved into the SIP on 

September 24, 2013 (78 FR 58459.)

5. SJVAPCD District Rule 4612, amended October 21, 2010, and approved into the 

SIP on February 13, 2012 (77 FR 7536.)

6. VCAPCD Rule 74.18, amended November 11, 2008, and approved into the SIP 

on September 24, 2013 (78 FR 58459.)

7. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,”

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (web citation).

8. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,”

(a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf)

9. National Volatile Organic Compound Emission Standards, 40 CFR § 59.102, 

Subpart B, Table 1,VOC Content Limits for Automobile Refinish Coatings.

10. CARB Resolution 05-46, October 20. 2005, Attachment A, “Suggested Control 

Measure for Automotive Coatings,” Section 4.1 “Coating Limits.”