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 451, Surface 

Coating of Miscellaneous Metal Parts and Products 

Prepared by: Nicole Law 

Reviewed by: Andrew Steckel

October 2011 
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RULE IDENTIFICATION - 

Agency: Sacramento Metropolitan Air Quality Management 

District (SMAQMD) 

SIP Approved Rule: Rule 451 – Surface Coating of Manufactured Metal 

Parts and Products 

Adopted – November 29, 1983; Submitted – April 19, 

1984 

EPA Approved – January 24, 1985 (50 FR 3338) 

Superseded Submittals: Amended - June 27, 1985; Submitted – February 10, 

1986 

 Amended – September 29, 1987; Submitted – March 

23, 1988 

 Amended- February 23, 1993; Submitted – April 6, 

1993; EPA proposed a limited approval/limited 

disapproval of the 1993 version, but never finalized 

this action 

 Amended – September 5, 1996; Submitted May 18, 

1998 

Amended – September 25, 2008; Submitted – 

September 15, 2009 

Subject of this TSD: Rule 451 – Surface Coating of Miscellaneous Metal 

Parts and Products 

 Amended – October 28, 2010; Submitted- April 5, 

2011 

RULE SUMMARY - 

Rule 451, Surface Coating of Miscellaneous Metal Parts and Products, limits 

VOC emissions from operations associated with the coating of miscellaneous 

metal parts and products in a shop environment. The rule establishes VOC 

limits for miscellaneous metal parts coatings, metal furniture coatings, and 

cleaning solvents associated with coating operations. The rule also describes 

emissions control equipment, recordkeeping requirements, and test methods 

used for determining VOC content and control efficiencies. Changes from the 

approved SIP rule include: 

1. The rule has been renamed to broaden the applicability of the rule. 

2. Section 101, the purpose, has been expanded to include limiting VOC 

emissions from all operations associated with coatings of miscellaneous 

metal parts and products. 

3. Sections 102 and 103, the applicability and severability sections have 

been added to the rule. 
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4. Several changes were made to the former Section 102, exemptions, now 

included in Sections 110 through 116. Please see rule for exemption 

edits. 

5. Added several new definitions in Section 200, including “automobile,” 

“etching filler,” “mask coating,” “metal furniture,” “multi-component 

coating,” and “stationary source.” Some definitions have also been 

updated, for example, the definitions for “metallic/iridescent coating” and 

“volatile organic compound.” 

6. Section 300, the standards, has been significantly updated to include new 

VOC limits for specialty categories and cleaning materials, lowered 

general coating VOC content limits, additional application methods, and 

alternative emission control system requirements. 

7. Section 400, the administrative requirements, has been significantly 

changed. The compliance schedule has been removed and in its place 

are sections describing the low usage exemption submittal, product 

information required of sellers, calculation guidance, and a section 

describing requirements of the operation and maintenance plan. 

8. Section 500, a monitoring and records section, has been added to 

describe recordkeeping requirements and test methods. 

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

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. RACT – EPA’s Control Technique Guidelines (CTGs) titled, “Control 

Techniques Guidelines for Miscellaneous Metal Parts Coatings” (EPAEPA-453/R-08-003, September 2008), “Control Techniques Guidelines for 

Metal Furniture Coatings” (EPA-453/R-07-005, September 2007), “Control 

of Volatile Organic Emissions From Existing Stationary Sources Volume III: 

Surface Coating of Metal Furniture” (EPA-450/2-77-032, December 1977), 

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). 

3. SIP Relaxation - Where previous versions of rules have been SIP 

approved, new submittals must comply with CAA §110(l) and §193 

regarding SIP relaxations. We have evaluated this 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 
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nonattainment area, any SIP-approved control requirement in effect before 

November 15, 1990 (CAA 193). 

The submitted rule is as generally as stringent as other California District rules for 

this category and EPA’s CTGs. As a result, we have determined that this rule 

fulfills RACT requirements. The monitoring, recordkeeping, reporting and other 

requirements generally ensure that the submitted rule can be enforced. Lastly, 

the submitted rule is more comprehensive than the version previously approved 

into the SIP, so the submitted rule does not relax the SIP and complies with 

§110(l) and §193. 

Rule 451 was amended to meet RACT requirements by complying with EPA’s 

2008 Miscellaneous Metal Parts Coating CTG and EPA’s 2007 Metal Furniture 

Coating CTG. Although not all categories from the Miscellaneous Metal Parts 

CTG were adopted into Rule 451, we have received confirmation from SMAQMD 

staff that those categories will be addressed in other rules and rule amendments. 

The rule adopts all the recommendations in the Metal Furniture Coating CTG, 

even though conversations with staff indicated there are no affected sources. 

The current SIP version of Rule 451 from 1983 only has two general limits for all 

miscellaneous metal parts, a limit for air dried coatings and a limit for baked 

coatings. Since that submittal, the rule has been amended several times, 

introducing more coating categories and seemingly higher limits. The introduction 

of specialty categories and new limits had no emission impacts associated with it, 

therefore we do not see this as a rule relaxation. In addition to new specialty 

categories and new limits, rule revisions introduced a surface preparation and 

cleaning materials VOC limit which has obtained an estimated 163 pounds of VOC 

per year emission reduction. With the inclusion of a cleaning material VOC limit, 

the increase in emission control efficiency, and exclusion of former exemptions, 

we consider these amendments as an overall strengthening of the rule. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 451 

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revision is not currently the basis for rule disapproval, but is 

recommended for the next time the rule is amended. 

• Please revise the date for ASTM D4457-02(2008) to ATSMD-4457-

85(1991). Only revisions specifically approved by the EPA can be used to 

demonstrate compliance with SIP. 

EPA ACTION - The submitted Rule 451 strengthens the SIP. The rule fulfills the 

relevant CAA §110 and part D requirements. EPA staff recommends a full 

approval of Rule 450 pursuant to CAA §110(k)(3) and §301(a). 
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REFERENCES - 

1. SMAQMD Rule 451, Surface Coating of Miscellaneous Metal Parts and 

Products, as submitted on April 5, 2011 

2. SMAQMD Rule 451, Surface Coating of Manufactured Metal Parts and 

Products, as approved into the SIP on January 24, 1985. 

3. “Control Technique Guidelines for Miscellaneous Metal and Plastic Parts 

Coatings,” EPA-453/R-08-003, September 2008. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-

003_misc_metal_plasticparts_coating.pdf

4. “Control Techniques Guidelines for Metal Furniture Coatings” EPA-453/R07-005, September 2007. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r-07-

005_metal_furniture_coating.pdf

5. “Control of Volatile Organic Emissions from Existing Stationary Sources 

Volume III: Surface Coating of Metal Furniture,” EPA-450/2-77-032, 

December 1977. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197712_voc_epa450_2-77-

032_surface_coatings(v3).pdf

6. “Control of Volatile Organic Emissions from Existing Stationary Sources 

Volume VI: Surface Coating of Miscellaneous Metal Parts and Products,” 

EPA-450/2-78-015, June 1978. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197806_voc_epa450_2-78-

015_surface_coatings(v6).pdf

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

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. 

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

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