# Antelope Valley Air Quality Management District

Final 

# Staff Report

for



# Amendment to 

# Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations

As amended on

June 19, 2012

43301 D IVISION 

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### , C ALIFORNIA 

### 93535-4649
P HONE 

### (661) 723-8070

FAX (661) 723-3450This page intentionally left blank.AVAQMD Rule 1151 TC-1 Staff Report, Final 06/04/12 

### STAFF REPORT
TABLE OF CONTENTS 

## Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations

I. PURPOSE OF STAFF REPORT ...........................................................................................1

II. EXECUTIVE SUMMARY....................................................................................................1

III. STAFF RECOMMENDATION............................................................................................3

IV. LEGAL REQUI REMENTS CHECKLIST ..........................................................................4

V. DISCUSSION OF LEGAL REQUIREMENTS...................................................................5

A. REQUIRED ELEMENTS/FINDINGS ..........................................................................5 1. State Findings Required for Adoption of Rules & Regulations ......................5 a. Necessity..............................................................................................5 b. Authority..............................................................................................5 c. Clarity ..................................................................................................5 d. Consistency..........................................................................................5 e. Nonduplication.....................................................................................7
f. Reference..............................................................................................7 g. Public Notice & Comment, Public Hearing ........................................7 2. Federal Elements (SIP Submittals, Other Federal Submittals) ............................7 a. Satisfaction of Underlying Federal Requirements..................................7
b. Public Notice and Comment..................................................................8 c. Availability of Document ......................................................................8 d. Notice to Specified Entities .................................................................8 e. Public Hearing ......................................................................................8 f. Legal Authority to Adopt and Implement ............................................9 g. Applicable State Laws and Regulations Were Followed ....................9

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ........................................9

C. ECONOMIC ANALYSIS ............................................................................................10
1. General...........................................................................................................10
2. Incremental Cost Effectiveness ....................................................................10

D. ENVIRONMENTAL ANALYSIS (CEQA) ................................................................10

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ...............................................11
1. Potential Envi ronmental Impacts...................................................................11 2. Mitigation of Impacts ....................................................................................12 3. Alternative Methods of Compliance..............................................................12TC-2 AVAQMD Rule 1151 Staff Report, Final 06/04/12 F. PUBLIC REVIEW........................................................................................................12

VI. TECHNICAL DISCUSSION.............................................................................................12

A. SOURCE DESCRIPTION ...........................................................................................12

B. EMISSIONS ............................................................................................................... ..12

C. CONTROL REQUIREMENTS....................................................................................12

D. PROPOS ED RULE SUMMARY.................................................................................13

E. SIP HISTORY ............................................................................................................. .15 1. SIP History.....................................................................................................15 2. SIP Analysis...................................................................................................16

Apendix A – Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations

Iterated Version.............................................................................................................. .... A-1

Appendix B - Public Notice Documents .....................................................................................B-1

Appendix C - Public Comments and Responses .........................................................................C-1

Appendix D - California Environmental Quality Act Documentation....................................... D-1

Appendix E - Bibliography...................................................................................................... ....E-1AVAQMD Rule 1151 1 Staff Report, Final 06/04/12 

### STAFF REPORT 

## Rule 1151 - Motor Vehicle and Mobile Equipment Coating Operations

I. PURPOSE OF STAFF REPORT

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and background material to the members of the Antelope Valley Air Quality Management District Governing Board (Governing Board). This allows the members of the Governing Board to be fully informed before making any required decision. It also provides the documentation necessary for the Governing Board to make any findings, which are requi red by law to be made prior to the approval or adoption of a document. In addition, a staff report ensures that the correct procedures and proper documentation for approval or adoption of a document have been performed. Finally, the staff report provides evidence for defense against legal challenges regarding the propriety of the approval or adoption of the document.

II. EXECUTIVE SUMMARY

The Governing Board is being requested to conduct a public hearing, make findings, certify the Negative Declaration, and then adopt a resolution amending Rule 1151 - Motor Vehicle and Mobile Equipment Coating Operations.

The Antelope Valley Air Quality Management Di strict (AVAQMD) has the authority pursuant to California Health and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules and regulations. The AVAQMD is proposing to amend Rule 1151 - Motor Vehicle and Mobile Equipment Coating Operations.

Pursuant to Health and Safety Code (H&S Code) § 40106, the, then, Antelope Valley Air Pollution Control District (AVAPCD) assumed all air pollution control responsibilities from the South Coast Air Quality Management District (SCAQMD) in the Lo s Angeles County portion of the Mojave Desert Air Basin effective July 1, 1997. The rules of the SCAQMD were to remain in effect in AVAPCD until such time as the Governing Board adopted, amended, or rescinded rules and regulations to supersede those existing rules (H & S Code §40106(e)).

Rule 1151 was originally adopted by SCAQMD on July 8, 1988 to reduce volatile organic compound (VOC) emissions from motor vehicle and mobile equipment coating operations within its jurisdiction including the Antelope Valley. Subsequently, the 1990 amendments to the Federal Clean Air Act (FCAA) required ozone non-attainment areas to implement Reasonably Available Control Technology (RACT) for sources that are subject to Control T echnique Guidelines (CTGs) and Alternative Control Technologies (ACTs) for major sources of ozone precursors (42 U.S.C. §§7511a). At that time SCAQMD, including the Antelope Valley had designated nonattainment for ozone; therefore Rule 1151, was amended in part to satisfy this federal requirement. At the time of adoption, it was recognized that some of the proposed VOC limits of Rule 1151 were, “technologically forcing”, in that no compliant products were available to meet the more stringent requirements. In 1994, the SCAQMD Governing Board amended Rule 1151 on December 9 th to delay the implementation of some2 AVAQMD Rule 1151 Staff Report, Final 06/04/12 requirements until July 1, 1997. By 1996 it became clear that no products were available for certain categories. A product variance from the Hearing Board was granted, extending the compliance deadline to December 18, 1997. After the creation of the AVAPCD, the final compliance date for the product variance was extended by the AVAPCD Hearing Board until September 8, 1999. In July of 1999, Rule 1151 was amended to extend the compliance date for certain coating categories to July 1,
2000.

Rule 1151 regulates emissions of volatile organi c compounds (VOCs) from coating operations of motor vehicle and mobile equipment. Rule 1151 applies to both commercial and noncommercial refinishing coating applications that include, but are not limited to, auto body repair/paint shops, production auto body paint shops, new car dealer repair /paint shops, fleet operators repair/paint shops, custom-made car fabrication facilities, truck body builders, and any other motor vehicle or mobile equipment painting operations. The current rule establishes VOC limits by coating category and vehicle type. The current coating categories include pretreatment wash primer, primer/primer surfacer, primer sealer, topcoat, metallic topcoat, multi-stage topcoat system, and extreme performance; and, there are currently two vehicle types: Group I and Group II. Group I vehicles include large sized trucks, buses and mobile equipment, whereas, Group II vehicles include passenger cars, small-sized and medium sized trucks and vans, motor homes, and motorcycles.

The proposed amendments to Rule 1151 modify the coating categories and VOC limits in accordance with the California Air Resources Board’s (CARB) Suggested Control Measure for Automotive Refinishing Coatings (SCM) as adopted on October 20, 2005. Specifically, the proposed amendments: (1) Combine Group I and Group II vehicle categories and establish VOC limits by coating category only; (2) Eliminate the composite VOC limit for multistage coating systems and establish independent VOC limit for both the color and clear parts of the multistage coating system; (3) Combine the primer, primer surfacer, and primer sealer categories and establish a single VOC limit for primers; and (4) Eliminate the general specialty coating category and replace it with specific categories, and VOC limits. The proposed amendments are technologically neutral, and the proposed VOC limit for color coating is based on waterborne products which are currently available. In addition, the proposed amendments incorporate the SCM for Automotive Refinishing Coatings ’ establishment of a 25 grams per liter VOC limit for cleaning and surface preparation solvents.

Concurrently with the amendments generated from the SCM, the revision of Rule 1151 includes proposed amendments generated from 40 Code of Federal Regulations (CFR) Part 63, Subpart

HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (Subpart HHHHHH), as well as, the Air Toxic Control Measure for Emissions of Hexavale nt Chromium and Cadmium from Motor Vehicle and Mobile Equipment Coatings (ATCM) (Title 17 CCR, §93112). These proposed amendments include labeling, monitoring, and record requirements for the targeted hazardous air pollutants of Subpart HHHHHH, and prohibits the manufacture of automotive coatings in which cadmium or hexavalent chromium was introduced as a pigment or as an agent to any part, any property or characteristic to the coatings during manufacturing, distribution, or use of the applicable coatings as defined by the ATCM.

As required by 42 U. S. C. §§7511a (FCAA §182), the revision of Rule 1151 included a close examination of all applicable CTGs and ACTs to ensure that RACT is being implemented by sourcesAVAQMD Rule 1151 3 Staff Report, Final 06/04/12 subject to Rule 1151. No amendments were necessary from this analysis, as the revised rule meets or exceeds the RACT defined in these applicable documents.

In addition, former H&S Code §39614(d) required the Antelope Valley Air Quality Management District (AVAQMD or District) to adopt the most r eadily available, feasible, and cost-effective local control measures for Particulate Matter (PM) as contained on a list developed by the CARB. CARB
has identified on its list of local control measures the “Vehicle Refinishing” strategy of limiting VOC content of applicable products to between 2.8-7.0 pounds per gallon. In the District’s List and Implementation Schedule for District Measures to Reduce PM Pursuant to Health & Safety Code §39614(d) the District identified this measure as currently implemented in the July 20, 1999 version of Rule 1151; therefore, no additional analysis is necessary.

The proposed amendments to Rule 1151 addresses the SCM, RACT SIP Analysis, and the PM Analysis commitments, in addition to, the federal and state regulations as applicable. The proposed amendment of Rule 1151 also updates the definitions; VOC content limits for different coating categories; VOC emission control system limits; solvent cleaning operation limits; and, exemptions, recordkeeping and test methods. Therefore, the District staff recommends amending Rule 1151.

III. STAFF RECOMMENDATION

Staff recommends that the Governing Board adopt the proposed amendments to Rule 1151 and approve the appropriate California Environmental Quality Act (CEQA) documentation. This action is necessary to modify the coating categories and VOC limits in accordance with CARB’s SCM and to implement amendments generated from Subpart HHHHHH and the ATCM.4 AVAQMD Rule 1151 Staff Report, Final 06/04/12 72

IV. LEGAL REQUIREMENTS CHECKLIST

The findings and analysis as indicated below are required for the procedurally correct amendment to
Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations . Each item is discussed, if applicable, in Section V below. Copies of documents are included in the appropriate Appendix.

FINDINGS REQUIRED FOR
RULES & REGULATIONS

X Necessity

X Authority

X Clarity

X Consistency

X Nonduplication

X Reference

X Public Notice & Comment

X Public Hearing

REQUIREMENTS FOR STATE
IMPLEMENTATION PLAN SUBMISSION (SIP):

X Public Notice & Comment

X Availability of Document

X Notice to Specified Entities (State, Air Districts, USEP A, Other States)

X Public Hearing

X Legal Authority to adopt and implement the document.

X Applicable State laws and regulations were followed. ELEMENTS OF A FEDERAL
SUBMISSION

X Elements as set forth in applicable Federal law or regulations.

CALIFORNIA ENVIRONMENTAL QUALITY ACT REQUIREMENTS (CEQA):

N/A Ministerial Action

X Exemption

N/A Negative Declaration

N/A Environmental Impact Report

X Appropriate findings, if necessary.

X Public Notice & Comment

SUPPLEMENTAL ENVIRONMENTAL ANALYSIS (RULES & REGULATIONS ONLY):

X Environmental impacts of compliance.

N/A Mitigation of impacts.

N/A Alternative methods of compliance.

OTHER:

X Written analysis of existing air pollution control requirements

X Economic Analysis

X Public ReviewAVAQMD Rule 1151 5 Staff Report, Final 06/04/12 V. DISCUSSION OF LEGAL REQUIREMENTS

A. REQUIRED ELEMENTS/FINDINGS

This section discusses the State of California st atutory requirements that apply to the proposed amendment to Rule 1151. These are actions, that need to be performed, and/or information, that must be provided in order to amend the Rule in a procedurally correct manner.

1. State Findings Required for Adoption of Rules & Regulations:

Before adopting, amending, or repealing a rule or regulation, the Governing Board is required to make findings of necessity, au thority, clarity, consistency, non-duplication, and reference based upon relevant information presented at the hearing. The information below is provided to assist the Board in making these findings.

a. Necessity:

The proposed amendments to Rule 1151 are necessary to modify the coating categories and VOC limits in accordance with the CARB’s SCM
, as well as, incorporate amendments generated from Subpart HHHHHH and the ATCM

b. Authority:

AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend or repeal rules and regulations.

c. Clarity:

The proposed amendments are clear in that they are written so that the persons subject to the rule can easily understand the meaning.

d. Consistency:

The proposed amendments to Rule 1151 are in harmony with, and not in conflict with or contradictory to any state law or regulation, federal law or regulation, or court decisions. USEPA has issued one CTG, and one ACT which have an impact on Rule 1151: CTG for Reduction for Volatile Organic Compound Emissions from Automobile Refinishing (EPA 450/3-88-009, 1988/10), and Alternative Control Techniques Document: Automotive Refinishing (EPA 453/R-94-031, 1994/04). These documents provide information on the application processes, VOC emissions and emission reductions, and costs associated with the use of alternative coating formulations and equipment used in automotive refinishing operations. The proposed VOC emission limits resulting from these products and technologies discussed in these documents are less stringent than those of the proposed amendments to Rule 1151, and therefore, these proposed amendments are not in conflict or inconsistent with the applicable CTG and ACT.6 AVAQMD Rule 1151 Staff Report, Final 06/04/12 While the following list of CTGs were determined to not be applicable to Rule 1151, they were reviewed in the rule development process: CTG for Control of Volatile Organic Emissions from Existing Stationary Sources – Volume I: Control Methods for Surface-Coating Operations (EPA-450/2-76-028, 1976/11), CTG for Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 1977/05),
CTG for Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and
Products (EPA-450/2-78-015, 1978/06), Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003, 2008/09),
and Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings (EPA-453/R-08-006, 2008/09).

There are no Federal New Source Performance Standards (NSPS) that are applicable to Rule 1151. During the rule amendment process, 40 CFR 60 Subpart MM, Standards of Performance for Automobile and Light Duty Truck Surface Coating Operations was examined, but was deemed to not be applicable to Rule 1151, as it only applies to assembly line operations.

There is one National Emission Standard for Hazardous Air Pollutant Maximum Achievable Control Technology (MACT) that applies to automotive refinishing: 40 CFR 63 Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations
at Area Sources . The proposed amendments to Rule 1151 satisfy the requirements of this standard; therefore, are not in conflict.

There is one Air Toxic Control Measure (ATCM) that applies to automotive refinishing: Title 17 CCR, Section 93112, Hexavalent Chromium and Cadmium Airborne Toxic Control Measure: Motor Vehicle and Mobile Equipment Coatings . The proposed amendments to Rule 1151 satisfy the requirements of this measure; therefore, are not in conflict.

The proposed amendments to Rule 1151 modify the coating categories and VOC limits in accordance with the California Air Resources Board’s (CARB) Suggested Control Measure for Automotive Refinishing Coatings (SCM) as adopted on October 20, 2005. Specifically, the proposed amendments: (1) Combine Group I and Group II vehicle categories and establish VOC limits by coating category only; (2) Eliminate the composite VOC limit for multistage coating systems and establish independent VOC limit for both the color and clear parts of the multistage coating system; (3) Combine the primer, primer surfacer, and primer sealer categories and establish a single VOC limit for primers; and (4) Eliminate the general specialty coating category and replace it with specific categories, and VOC limits. The proposed amendments are technologically neutral, and the proposed VOC limit for color coating is basedAVAQMD Rule 1151 7 Staff Report, Final 06/04/12 on waterborne products which are currently available. In addition, the proposed amendments incorporate the SCM for Automotive Refinishing Coatings ’s establishment of a 25 grams per liter VOC limit for cleaning and surface preparation solvents.

e. Nonduplication:

The proposed amendments to Rule 1151 do not impose the same requirements as any existing state or federal law or regulation because the District is adopting this rule in response to CARB’s SCM, Subpart HHHHHH, and the ATCM.

f. Reference:

AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend or repeal rules and regulations. The proposed amendments to Rule1151 implement and comply with CARB’s SCM (2005/10), 40 CFR 63 Subpart HHHHHH, and the ATCM (Title 17 CCR §93112).

g. Public Notice & Comment, Public Hearing:

Notice for the public hearing for the proposed amendments to Rule 1151 was originally published June 17, 2011. Since the rule was continued to the A ugust 16 th meeting and then pulled from the agenda at that meeting, a new notice for the public hearing for the proposed amendments to Rule 1151 was published on April 13, 2012. See Appendix “B” for a c opy of the public notice. See Appendix “B” for a copy of the public notice. See Appendix “C” for copies of comments, if any, and AVAQMD responses. The proposed amendment of Rule 1151 was originally scheduled for the July, 19, 2011 Governing Board meeting, which was cancelled, so this item was continued to the August 16, 2011 meeting. At that meeting, the item was pulled from the agenda in order to readdress comments from the public. After addressing the comments from the August 16, 2011 meeting, the proposed amendments to 1151 were noticed for the May 15, 2012 meeting. At the May 15, 2012 meeting the Governing Board asked that this item be continued to the June 19, 2012 meeting.

2. Federal Elements (SIP Submittals, Other Federal Submittals).

Submittals to USEPA are required to include various elements depending upon the type of document submitted and the underlying Federal law which requires the submittal. The information below indicates which elements are required for the proposed amendment to Rule 1151 and how they were satisfied.

a. Satisfaction of Underlying Federal Requirements:8 AVAQMD Rule 1151 Staff Report, Final 06/04/12 The FCAA requires areas designated non-attainment and classified moderate and above to implement RACT for sources subject to CTG and ACT documents
60

issued by USEPA for major sources of VOCs and oxides of nitrogen (NO X ) which are ozone precursors. USEPA has issued one CTG, and one ACT which have an impact on Rule 1151: CTG for Reduction for Volatile Organic Compound Emissions from Automobile Refinishing (EPA 450/3-88-009, 1988/10), and Alternative Control Techniques Document: Automotive Refinishing (EPA 453/R-94-031, 1994/04). These documents provide information on the application processes, VOC emissions and emission reductions, and costs associated with the use of alternative coating formulations and equipment used in automotive refinishing operations. The VOC emission limits resulting from these products and technologies discussed in these documents are less stringent than those of the amendments to Rule 1151. To ensure that the amendments to Rule 1151 will satisfy the RACT requirements pursuant to FCAA, the revisions made to the rule are consistent with the requirements of San Joaquin Valley Unified Air Pollution Control District’s (SJVUAPCD) Rule 4612: Motor Vehicle and Mobile Equipment Coating Operations – Phase II , as amended on September 20, 2007 and approved into the SIP as RACT by USEPA on January 1, 2010 (75 FR 2796).

b. Public Notice and Comment:

Notice for the public hearing for the proposed amendments to Rule 1151 was originally published on June 17, 2011. Since the rule was continued to August
16 th meeting and then pulled from the agenda at that meeting, a new notice for the public hearing for the proposed amendments to Rule 1151 was published on April 13, 2012. See Appendix “B” for a c opy of the public notice.

c. Availability of Document:

Copies of the proposed amendments to Rule 1151 and the accompanying draft staff report was made available to the public on or before April 13, 2012.

d. Notice to Specified Entities

Copies of the proposed amendments to Rule 1151 and the accompanying draft staff report were sent to all affected agencies. The proposed rule amendments were sent to CARB and USEPA on or before April 13, 2012.

e. Public Hearing:

The proposed amendment of Rule 1151 was originally scheduled for the July, 19, 2011 Governing Board meeting, which was cancelled. This item was continued to the August 16, 2011. At that meeti ng, the item was pulled from the agenda inAVAQMD Rule 1151 9 Staff Report, Final 06/04/12 order to readdress comments from the public concerning Single-stage Coatings and Vinyl Interior Coatings availability for the proposed VOC limits. The proposed amendment of Rule 1151 was then re-noticed for the May 15, 2012 meeting. At the May 15, 2012 meeting the Governing Board asked that this item be continued to the June 19, 2012 meeting.

f. Legal Authority to Adopt and Implement:

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend, or repeal rules and regulations and to do such acts as may be necessary or proper to execute the duties imposed upon the AVAQMD.

g. Applicable State Laws and Regulations Were Followed:

Public notice and hearing procedures pursuant to H&S Code §§40725-40728 have been followed. See Section (V)(A)(1) above for compliance with state findings required pursuant to H&S Code §40727. See Section (V)(B) below for compliance with the required analysis of existing requirements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance with economic analysis requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for compliance with provisions of the California Environmental Quality Act (CEQA).

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS

H & S Code §40727.2 requires air districts to prepare a written analysis of all existing federal air pollution control requirements that apply to the same equipment or source type as the rule proposed for modification by the District.

The FCAA requires areas designated non-attainment and classified moderate and above to implement RACT for sources subject to CTG and ACT documents issued by USEPA for major
sources of VOC and NO X which are ozone precursors. USEPA has issued one CTG, and one ACT which have an impact on Rule 1151: CTG for Reduction for Volatile Organic Compound Emissions from Automobile Refinishing (EPA 450/3-88-009, 1988/10), and Alternative Control Techniques Document: Automotive Refinishing (EPA 453/R-94-031, 1994/04). These documents provide information on the application processes, VOC emissions and emission reductions, and costs associated with the use of alternative coating formulations and equipment used in automotive refinishing operations. The VOC emission limits resulting from these products and technologies discussed in these documents are less stringent than those of the amendments to Rule 1151. To ensure that the amendments to Rule 1151 will satisfy the RACT requirements pursuant to FCAA, the revisions made to the rule are consistent with the requirements of SJVUAPCD’s Rule 4612: Motor Vehicle and Mobile Equipment Coating Operations – Phase II , as amended on September 20, 2007 and approved into the SIP as RACT by USEPA on January 1, 2010 under Federal Registration Citation Number 75 FR 2796. Therefore, rule adoption at the local level and submission as a SIP revision is necessary to implement these requirements.10 AVAQMD Rule 1151 Staff Report, Final 06/04/12 There is one National Emission Standard for Hazardous Air Pollutant Maximum Achievable Control Technology (MACT) that applies to automotive refinishing: 40 CFR Part 63 Subpart

HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources . The amendments to Rule 1151 satisfy the requirements of this standard; theref ore, are not in conflict. MACT standards are imposed upon existing sources pursuant to the provisions of District Rule 1402 – Control of Toxic Air Contaminants from Existing Sources . Thus, many of the existing sources are already subject to the same level of control for certain chemicals as those specified in the amendments to Rule 1151. Please note that any new or modifi ed stationary source in this category would require a Toxic New Source Review analysis as part of its permitting process (see District Rule 1401) and would thus acquire the same level of control as that provided for by amended
Rule1151.

C. ECONOMIC ANALYSIS

1. General

The proposed amendments to Rule 1151 is equivalent to SJVUAPCD’s Rule 4612 – Motor Vehicle and Mobile Equipment Coating Operations – Phase II , which was determined by USEPA to be RACT (75 FR 2796); therefore, cost effectiveness is not required.

2. Incremental Cost Effectiveness

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are required for rules and regulations which are adopted or amended to meet the California Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) or “all feasible measures” to control volatile compounds, oxides of nitrogen or oxides of
sulfur.

The proposed amendment to Rule 1151 are not subject to incremental cost effectiveness calculations because this rule does not impose BARCT or “all feasible measures”.

D. ENVIRONMENTAL ANALYSIS (CEQA)

Through the process described below, it was determined that a Notice of Exemption would be the appropriate CEQA process for the proposed amendment to Rule 1151.

1. The proposed amendment to Rule 1151 meet the CEQA definition of "project." They are not "ministerial" actions.

2. The proposed amendment to Rule 1151are exempt from CEQA review because it will not create any adverse impacts on the environment. The requirements in the amendments to Rule 1151 are more stringent than the currently existing requirements (see more detailed discussion in Rule Summary §(D)) in that: theAVAQMD Rule 1151 11 Staff Report, Final 06/04/12 rule applicability is expanded in accordance with the SCM; definitions are updated to make the rule more comprehensive, reflect the current applicability of the rule, and provide additional clarity; VOC limits for various categories of coatings and solvent coating operations have been modified in accordance with the SCM; work practice requirements have been added; and, the monitoring and recordkeeping, and test method sections have been strengthened. Concurrently with the amendments generated from the SCM, the revision of Rule 1151 also includes amendments generated from Subpart HHHHHH and the ATCM which includes labeling, monitoring, and record requirements for the targeted hazardous air pollutants of Subpart HHHHHH, and prohibits the manufacture, sell, offering for sale, distribution for use in the District, and/or application of automotive coatings which contain cadmium or hexavalent chromium. This includes those coatings in which cadmium or hexavalent chromium was introduced as a pigment or as an agent to any part, any property or characteristic to the coatings during manufacturing, distribution, or use of the applicable coatings as defined by the ATCM.

In addition, coatings satisfying the limits contained in the rule are readily available in commerce and have been shown not to cause either additional usage of the coatings themselves or of cleaning solvents. Other air districts have adopted similar rules, and neither they, nor USEPA, have identified increased usage of coatings or solvents as an issue in supporting documentation.

Therefore, no adverse environmental effects are foreseen from the amendments. Copies of the documents relating to CEQA can be found in Appendix “D”

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential adverse environmental impacts of compliance with the adoption of Rule 1151. The amendments to Rule 1151 modify the coating categories, and reduce the VOC limits for these coatings and associated solvents in accordance with CARB’s SCM. Also in accordance with the SCM, the amendments enhance the rule’s applicability and increases clarification through definitions and reporting requirements. The revision of Rule 1151 also includes amendments generated from Subpart HHHHHH and the ATCM in order to strengthen labeling, monitoring, and record requirements for the targeted hazardous air pollutants and prohibits the manufacture, sell, offering for sale, distribution for use in the District, and/or application of automotive coatings which contain cadmium or hexavalent chromium. This includes those coatings
in which cadmium or hexavalent chromium. These amendments are more stringent than the current adopted requirements of Rule 1151, and coatings complying with the rule VOC limits are readily available in commerce and should not cause additional usage of the coatings themselves or of cleaning solvents. These more stringent requirements should help to further abate the12 AVAQMD Rule 1151 Staff Report, Final 06/04/12 emission of air contaminants generated from automotive refinishing operations. In fact, the District suspects that a high percentage of the facilities in this source category are already using compliant coatings, or are prepared to do so upon adoption of the amendments, due to availability and the fact that the SCM has already been incorporated into the analogous automotive refinishing rules of neighboring air districts, such as SCAQMD and SJVUAPCD.

2. Mitigation of Impacts

N/A

3. Alternative Methods of Compliance

N/A

F. PUBLIC REVIEW

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix B.

VI. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

Rule 1151 is aimed at automotive refinishing operations, and those which manufacture, distribute, and sell automotive coatings. Specifically, this rule will be applicable to any person who uses, applies, or solicits the use or application of any automotive coating or associated solvent within the District, and also, any person who supplies, sells, offers for sale, manufacturer’s, or distributes any automotive coati ng or associated solvent within the District. Previously, suppliers, sellers, manufacturers, and distributors were not applicable to Rule 1151. The SCM includes this group in order to promote consistency and uniformity statewide.

Several facilities in the AVAQMD have operations potentially affected by the amendments to Rule 1151. There are approximately 47 automotive refinishing operations within the District which are served by about three main suppliers. There are several manufacturers of automotive coatings who distribute their products throughout the state, as well as, nationwide.

B. EMISSIONS

The amendments to Rule 1151 do not cause the release of additional air contaminants, or create any adverse environmental impacts because the amended rule proposes a more stringent applicability, as well as, more stringent VOC limits for all coating categories, including solvent cleaning operations, than the existing rule. It also places prohibitions and/or restrictions on hazardous air pollutants and toxic compounds that may be found in automotive coatings or operations, that were not previously regulated by Rule 1151.

C. CONTROL REQUIREMENTSAVAQMD Rule 1151 13 Staff Report, Final 06/04/12 Please see subsections (C)(1) through (C)(8) of the rule (see Appendix “A”) for control requirements. Control requirements are in the form of VOC limits for coatings and solvents, approved VOC emission control system limits, prohibitions of hazardous air pollutants and toxics, approved coating application equipmen t, prohibition of possession, specification and sale, and surface preparation and cleaning operation practices.

D. PROPOSED RULE SUMMARY

This section gives a brief overview of the amendments to Rule 1151. The iterated rule version is contained in Appendix “A” of this staff report.

The amendments to Rule 1151 were designed to implement CARB’s SCM, as well as, provisions generated from Subpart HHHHHH and ATCM.

Section (A), General , has been amended to extend applicability to any person who supplies, sells, offers for sale, manufactures, or distributes any automotive coating or associated solvent
within the District. A subsection was also adde d to specifically state what this rule does not apply to.

Section (B), Definitions , is updated. Definitions have been included to make the rule more comprehensive, reflect the current applicability of the rule, and provide additional clarity.

Section (C), Requirements, have been modified as follows:

VOC Content of Coatings , subsection (C)(1), combines Group I and Group II vehicle categories and establish VOC limits by coating category only; eliminates the composite VOC limit for multistage coating systems and establish independent VOC limit for both the color and clear parts of the multistage coating system; combines the primer, primer surfacer, and primer sealer categories and establish a single VOC limit for primers; and eliminates the general specialty coating category and replaces it with specific categories, and VOC limits.

The Most Restrictive VOC Limit requirement of subsection (C)(2) states that the lowest applicable VOC content limit in Table 1 shall apply if more than one category of coating is described on a container of automotive coating.

Alternative Compliance , subsection (C)(3), specifically states Emission Control System requirements are specified in subsection (C)(3)(a) which defines a new control efficiency of 85 percent and Alternative Emission Control Plan , subsection (C)(3)(b), allows for alternative compliance pursuant to Rule 108 – Alternative Emissions Control Plans

.

Prohibited Compounds in subsection (C)(4) and Carcinogenic Materials in subsection (C)(5) prohibit automotive coatings containing certain potentially toxic compounds and cadmium and
hexavalent chromium.

Approved coating application equipment and methods are discussed under Application Methods, subsection (C)(6). This subsection has been modified to require any other coating14 AVAQMD Rule 1151 Staff Report, Final 06/04/12 application approved by the Air Pollution Control Officer/Executive Director to be capable of achieving a transfer efficiency equivalent to, or higher than, the application methods listed in subsections (6)(a)(i) and (6)(a)(ii), but not less than 65 percent.

Subsection (C)(7), Surface Preparation and Cleaning Operations, has been amended to incorporate the SCM establishment of a 25 grams per liter VOC limit for cleaning and surface preparation solvents. This subsection has also been amended to clarify that spent solvent shall be stored in “vapor tight” and closed containers. Language was also added under this subsection to prohibit possession of non-compliant solvents after the compliance date of May 1, 2013. Language was also added for an exemption of aerosol solvent products, not to exceed 160 fluid ounces per day per facility.

Prohibition of Possession, Specification, and Sale , subsection (C)(8), has been modified to eliminate language referring to Group I and Group II designation which was removed by the SCM, and adds specific language in which subsection (C)(1) does not apply such as if an approved Emission Control System is used, the coating is located at a training center for educational purposes, or the coating is a prototype.

The current subsections of Specialty Coatings and Extreme Performance Coating Requirements have been removed in the amendment to Rule 1151, as these categories have been eliminated by the SCM.

Section (D), Exemptions , has been updated to be more comprehensive and to reflect the applicability of the rule. Specific exemptions from the SCM were also incorporated into this section under subsections (D)(1)(a), (D)(1)(b), (D)(1)(d), and (D)(1)(e) to exclude assembly line coatings, coatings for sale out side the District, aerosol coatings, and coatings sold in 0.5 fluid ounces or less, respectively.

Subsection (D)(4) and (D)(5) have been added to exempt automotive coatings applied for educational purposes and assembly-line coatings, respectively, with certain restrictions
consistent with those of the SCM.

Rule 442 Applicability , subsection (D)(6), has been incorporated under the Exemption section
from Administrative Requirements section as requested by CARB’s comment on the preliminary draft.

Section (E), Administrative Requirements , has been updated to reflect the applicability. Specifically, Manufacturer’s Compliance Statement Requirement , subsection (E)(1), and Manufacturer’s Labeling Requirement, subsection (E)(2), have been added to strengthen and clarify recordkeeping requirements. The Extreme Performance Coating Petition subsection has been removed in the revision of Rule 1151 as the SCM eliminates the “extreme performance” coating category.

Section (F), Monitoring and Records , has also been updated to strengthen and clarify recordkeeping requirements in accordance with the SCM and HHHHHH.AVAQMD Rule 1151 15 Staff Report, Final 06/04/12 Section (G), Test Methods , has been amended to update the testing methods and protocols to the most recent version in accordance with the SCM and those that are USEPA approved. Testing methods for the Determination of Methyl Acetate, Acetone, Acetate, and PCBTF
Content (subsection (G)(h)), Exempt Compound Content (subsection (G)(j)), Determination of Alternative Compliance (subsection (G)(i)), and HVLP Equivalency (subsection (G)(k)) were
also added.

Various format changes were made for consistency with current District rule format, as well as correction of typographical errors and several grammatical changes.

E. SIP HISTORY

1. SIP History.

Prior to 1975 the original air district for the Antelope Valley region was the Los Angeles County Air Pollution Control District that had jurisdiction covering the entire county of Los Angeles. In 1975, the Southern California Air Pollution Control District (So. Cal. APCD) was created by a Joint Powers Agreement (JPA) between Los Angeles, Orange, Riverside and San Bernardino Counties to replace the previous countywide air pollution control districts for those counties. On February 1, 1977, pursuant to statute (Cal. Stats. 1976, Ch 324 p. 815), the South Coast Air Quality Management District (SCAQMD) was created with an initial jurisdiction that only included areas of Los Angeles, Orange, Riverside and San Bernardino Counties contained within the South Coast Air Basin (SCAB). Outlying areas remained under the So. Cal. APCD (The legislation was thereafter amended to allow non-SCAB areas to “opt in”. Los Angeles County exercised this option and thus the Antelope Valley became a part of SCAQMD). Also on February 1, 1977 the California Air Resources Board (CARB) issued Executive Order G-73 (1977) which adopted a “rule book” for those non-SCAB areas of Los Angeles, Riverside and San Bernardino Counties. CARB submitted the G-73 rulebook on behalf of the “county” districts. By its terms Executive Order G-73 (1977) was only effective until th e non-SCAB areas took other action. On February 22, 1977 the JPA forming the So. Cal. APCD was formally dissolved. By the terms of the JPA upon dissolution each county would regain its county air pollution control district with a jurisdiction of the non-SCAB areas of the county and the applicable rules being the So. Cal. APCD’s rules in effect upon the date of dissolution. This rule book was the initial starting point for the SCAQMD rules applicable to the Antelope Valley.

On July 1, 1997 the Antelope Valley Air Pollution Control District (AVAPCD) replaced the SCAQMD as the agency with jurisdiction over the Los Angeles County portion of the Mojave Desert Air Basin (MDAB). Pursuant to the statutory change, the rules and regulations of the predecessor district were retained until the Governing Board adopted, amended or rescinded them. At its first meeting the AVAPCD reaffirmed all the existing rules and regulations thus the version in effect at the time of the change was the December 13, 1996 version.16 AVAQMD Rule 1151 Staff Report, Final 06/04/12 On January 1, 2002 the AVAPCD was replaced by the AVAQMD. Once again, pursuant to statute, the rules in effect were retained until the Governing Board adopted, amended, or rescinded. Similarly, at the first meeting of the AVAQMD, the Governing Boards reaffirmed all the rules and regulations in effect at the time the agency changed.

The jurisdiction of the AVAPCD and the AVAQMD were specified in the statutes as the portion of the Los Angeles County contained within the MDAB. The MDAB was formerly known as the Southeast Desert Air Basin (SEDAB). In 1997 the SEDAB was split into the MDAB and the Salton Sea Air Basin. Descriptions of these air basins can be found in 17 Cal. Code Regs. §§60109 and 60144. Since USEPA adopts State Implementation Plan (SIP) revisions in California as effective within jurisdictional boundaries of local air districts, when the lo cal air district boundaries change the SIP as approved by USEPA for that area up to the date of the change remains as the SIP in that particular area. Thus, upon creation of the AVAPCD on July 1, 1997 the AVAPCD acquired the SIP applicable to the Antelope Valley portion of the SCAQMD that was effective as of June 30, 1997. Likewise the AVAQMD acquired the SIP that was effective in the jurisdiction of the AVAPCD as of December 31, 2000. Therefore, the SIP history for this region is based upon the rules adopted, effective, and approved for the Antelope Valley by SCAQMD.

Rule 1151 was originally adopted on July 8, 1988, and was submitted as an amendment to the SIP. Rule 1151 was thereafter amended on May 5, 1989; March 2, 1990; June 28, 1990; November 2, 1990; December 7, 1990; and August 2, 1991. Rule 1151 was further amended on September 6, 1991 and submitted as a SIP amendment which promulgated a limited approval/limited disapproval (58 FR 66286; 40 CFR 52.220(c)(i)(A)(1)). On December 9, 1994 SCAQMD amended Rule 1151 and was submitted as a SIP amendment and it was approved into the SIP on June 13, 1995 (60 FR 31084; 40 CFR 52.220(c)(214)(A)(i)). Since this approval, Rule 1151 has been amended by SCAQMD two times times: March 8, 1996 and June 13, 1997. After the creation of the AVAPCD the AVAPCD amended Rule 1151 on July 20, 1999. The July 20, 1999 version was approved into the SIP on April 10, 2000 for the AVAQMD and is the current version in the SIP (65 FR 18901; 40 CFR 52.220(c)(270)(i)(E)(1)).

2. SIP Analysis.

The District will request CARB to submit the amendments to Rule 1151 to replace the SIP version in effect in the AVAQMD. This submission is necessary because the District wishes to update the SIP for this category.

Since there is a previously existing SIP rule for this category the District will request that it be superseded. In order to replace existing SIP rules the District is required to show that the amendments are not less stringent than the provisions currently in the SIP.

The amendment of Rule 1151 is more stringent than the provisions currently in the SIP because rule applicability has been expanded in accordance with the SCM; definitionsAVAQMD Rule 1151 17 Staff Report, Final 06/04/12 are updated to make the rule more comprehensive, reflect the current applicability of the rule, and provide additional clarity; VOC limits for various categories of coatings and solvent coating operations have been modified; work practice requirements have been added; and, the monitoring and recordkeeping, and test method sections have been strengthened. These amendments conform the current rule to those contained in the
SCM.

Concurrently with the amendments generated from the SCM, the revision of Rule 1151 also includes amendments generated from Subpart HHHHHH and the ATCM which consists of labeling, monitoring, and record requirements for the targeted hazardous air pollutants of Subpart HHHHHH, and prohibits the manufacture, sell, offering for sale, distribution for use in the District, and/or application of automotive coatings which contain cadmium or hexavalent chromium. This includes those coatings in which cadmium or hexavalent chromium was introduced as a pigment or as an agent to impart any property or characteristic to the coati ngs during manufacturing, distribution, or use of the applicable coatings as defined by the ATCM.18 AVAQMD Rule 1151 Staff Report, Final 06/04/12 This page intentionally left blank.AVAQMD Rule 1151 A-1 Staff Report, Final 06/04/12 

### APPENDIX "A" 

## Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations

Iterated Version

The iterated version is provided so that the changes to an existing rule may be easily found. The manner of differentiating text is as follows:

1. Shaded text identifies new or revised language.

2. Lined out text identifies language which is being deleted.

3. Normal text identifies the current language of the current rule which will remain unchanged by the adoption of the proposed amendments.

4. Italicized text identifies explanatory material that is not part of the proposed language.A-2 AVAQMD Rule 1151 Staff Report, Fianl 06/04/12 This page intentionally left blank.( Adopted: 07/08/88; Amended : 05/05/89; Amended : 03/02/90;
Amended : 06/28/90; Amended : 11/02/90; Amended : 12/07/90;
Amended : 08/02/91; Amended : 09/06/91; Amended : 12/09/94;
Amended : 03/08/96; Amended : 06/13/97; Amended : 07/20/99;
Amended : mmddyy)

AVAQMD Rule 1151 1151-1 Motor Vehicle and Mobile Equipment Coating Operations D6, 05/14/12 

## Rule 1151
Motor Vehicle a A nd Mobile Equipment Coating Operations

(A) Purpose and Applicability General

(1) Purpose

(a) The purpose of this rule is to reduce emissions of Volatile Organic Compounds ( VOCs ), from Coatings and solvents applied associated with the Refinishing on of

Motor Vehicles, Mobile Equipment and their Associated P p arts and
components Components

. [Changes derived from CARB’s SCM for Automotive Coatings, section 1]

(2) Applicability

(a) This rule This rule is applicable to:

(i) Any Person who uses, applies, or, solicits the use or application of any Automotive Coating or associated solvent within the District. (ii) Any Person who supplies, sells, offers for sale, manufactures, or distributes any Automotive Coating or associated solvent for use within
the District.

(b) This rule does not apply to:

(i) Any Coating applied to Motor Vehicles or Mobile Equipment, or their Associated Parts and Components, during manufacture on an Assembly
Line. (ii) Any Automotive Coating or associated solvent that is offered for sale, sold or manufactured for use outside of the District or for shipment to other manufacturers for reformulation or repackaging. (iii) Any Stencil Coating Product. (iv) Any Aerosol Coating Products that are in compliance with regulations and requirements adopted by the California Air Resources Board (CCR, Title 17, Subchapter 8.5, Section 94522). [Definition modified in response to ARB’s comment to do so in review of D2] (v) Any Automotive Coating that is sold, supplied, or offered for sale in one-half (0.5) fluid ounce or smaller containers intended to be used by1151-2 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 the general public to repair tiny surface imperfections. [This section added in response to USEPA’s comment of the preliminary draft requesting to add section here stating what the rule does not apply to. Reordering in response to ARB comment of D2] applies to all Commercial and Non

- Commercial Coating Applications to Group I Vehicles and Equipm ent and Group II Vehicles and their parts and components at facilities involved in the production, m odification, or refinishing of Motor Vehicles and Mobile Equipment.

(b) The application of Coatings on a vehicle which is not self

- propelled, such as
trail ers and mobile homes, are subject to other source specific rules contained in Regulation XI. [Changes derived from CARB’s SCM for Automotive Coatings, section 2]



### (B) Definitions

For the purposes of this rule, the following definitions shall apply:

(1) “Adhesion Promoter ” - A Coating which is labeled and formulated to be applied to uncoated plastic surfaces to facilitate bonding of subsequent Coatings, and on which, a subsequent Coating is applied. a Coating applied over both an existing non

- sanded Topcoat, and the coated area immediately adjacent to the non

- sanded Topcoat, to promote the adhesion of a subsequent Topcoat. No Topcoat, Primer, or Primer Surfacer
shall be classified as an Adhesion Promoter. [Changes to definition derived from CARB’s SCM for Automotive Coatings, section 3.18. Last sentence deleted as it conflicted with definition (B)(19), Coating Categories]

(2) “Aerosol Coating Product ” - a A pressurized Coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand-held application, or for use in specialized equipment for ground traffic/marking applications.

(3) “Air Pollution Control Officer (APCO)” - The person appointed by the Air Pollution Control Board and assigned full time to manage and direct the business and operations
of the district. The Air Pollution Control Officer is also the District Director, and is that person described for State purposes as the Air Pollution Control Officer. [Definition added for clarification purposes only]

(4) “Alternative Emission Control Plan” - A plan which allows a source to demonstrate an alternative method of rule compliance.

( 3 5 ) “Anti-Glare Safety Coating ” - a Coating formulated to eliminate glare for safety purposes on interior surfaces of a vehicle and which shows a reflectance of 25 or less on a 60° gloss meter.AVAQMD Rule 1151 1151-3 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (4) “ Basecoat ”

- a pigmented Topcoat which is the first Topcoat applied as part of a Multistage Topcoat System. [Deleted as this coating category no longer exists in CARB’s SCM for Automotive Coatings]

(5) “ Basecoat/Clearcoat Topcoat System ”

- a Multistage Topcoat System composed of a Basecoat portion and a Clearcoat portion.

(a) The Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds o f a Basecoat/Clearcoat Topcoat System shall be calculated according to the following formula:

VOC bc + 2 VOC cc VOC ms = 3

Where:

VOC ms = the composite Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds to be used for complia nce determination under the Multistage Topcoat System Coating category.
VOC bc = the Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds as applied, of any given Basecoat.
2 VOC
cc = two times the Grams of VOC per Liter of Coating Less W ater and Less Exempt Compounds as applied, of any given Clearcoat.

(b) The VOC per Volume of Applied Solids of a Basecoat/Clearcoat Topcoat System shall be calculated according to the following formula:

VOC

- S bc + 2 VOC

- S cc VOC

- S ms = 3

Where:

V OC

- S ms = the composite VOC per Volume of Applied Solids to be used for compliance determination under subsection (C)(1)(a)(ii)2.
VOC

- S bc = the VOC per Volume of Applied Solids of any given basecoat, calculated according to the formula in subsection (B)(51 ).
2 VOC

- S
cc = two times the VOC per Volume of Applied Solids of any given clearcoat, calculated according to the formula in subsection (B)(51). [Deleted to synchronize definitions with CARB’s SCM for Automotive Coatings. Definition is no longer necessary]1151-4 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (6) “Assembly Line” - An arrangement of industrial equipment and workers in which the product passes from one specialized operation to another until complete by either
automatic or manual means. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.3]

(7) “Associated Parts and Components” - Structures, devices, pieces, modules, sections, assemblies, subassemblies, or elements of Motor Vehicles or Mobile Equipment that are designed to be part of Motor Vehicles or Mobile Equipment but which are not attached to Motor Vehicles or Mobile Equipment at the time of coating the structure, device, piece, module, section, assembly, subassembly, or element. The Associated Parts and Components definition does not include circuit boards. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.4]

(8) “ASTM” - American Society for Testing and Materials [Definition added for clarification purposes only]

(9) “Automotive Coating” - Any coating or Automotive Coating Component, used or recommended for use, in Motor Vehicle or Mobile Equipment Refinishing, service, maintenance, repair, restoration, or modification, except metal plating activities. Any reference to automotive Refinishing or Automotive Coating made by a Person, on the container, or in product literature constitutes a recommendation for use in Motor Vehicle or Mobile Equipment Refinishing. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.5]

(10) “Automotive Coating Component” - Any portion of a coating, including, but not limited to, a Reducer or thinner, toner, hardener, and Additive, which is recommended by any person to distributors or end-users, for use in an Automotive Coating, or which is supplied for or used in an Automotive Coating. The raw materials used to produce the components are not considered Automotive Coating Components. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.6]

(11) “Automotive Refinishing Facility” - Any shop, business, location, or parcel of land where Motor Vehicles or Mobile Equipment or their Associated Parts and Components are coated, including autobody collision repair shops. Automotive Refinishing Facility does not include the original equipment manufacturing plant where the Motor Vehicle or Mobile Equipment is completely assembled. [Derived from SCAQMD Rule 1151, section (c)(7)]

( 6 12 ) “Bright Metal Trim Repair Coating ” - a A Coating applied directly to chrome-plated metal surfaces for the purpose of appearance.

( 7 13 ) “Bus ” - any Any Motor Vehicle having a manufacturer's gross vehicle weight of more than 8600 pounds and which is designed primarily for the transportation of persons, and having a design capacity of over 12 persons.AVAQMD Rule 1151 1151-5 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (8) “ Clearcoat ”

- a Topcoat which contains no pigments or only transparent pigme nts and which is the final Topcoat applied as a part of a Multistage Topcoat System. [Replaced with “Clear Coating”]

(14) “ CARB” – California Air Resources Board [Definition added in response to USEPA’s comment to do so on the preliminary draft.]

(15) “CFR” - Code of Federal Regulations [Definition added for clarification purposes only]

(16) “Cleaning Operations” - The removal of l oosely held uncured adhesives, inks, Coatings, or contaminants, including, but not limited to, dirt, soil, or grease, from Motor Vehicles, Mobile Equipment, Associated Parts and Components, substrates, parts, products, tools, machinery, equipment, or general work areas. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.9]

(17) “Clear Coating” - Any coating that contai ns no pigments and is labeled and formulated for application over a Color Coating or Clear Coating. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.10]

( 9 18 ) “Coating ” - a A material which is applied to a surface and which forms a film in order to beautify and/or protect such surface.

(19) “Coating Categories” - The table below shows Coating Categories prior to the 05/01/2013 compliance deadline, and the corresponding Coating Categories after the 05/01/2013 compliance deadline:

Comparison of Coating Categories
Coating Categories Prior to 05/01/2013 Coating Categories 05/01/13 and After

Adhesion Promoter Adhesion Promoter
Anti-glare Safety Coating Clear Coating, Color Coating, or SingleStage Coating
Bright Metal Trim Repair Coating Any Other Coating Type Camouflage Color Coating

Elastomeric Materials Primer, Color Coating, Clear Coating, Single-stage Coating, or Underbody Coating General Topcoat Single-Stage Coating Gloss Flatteners (aka Low-Gloss Coatings) Clear Coating

Heat Resistant Primer, Color Coating, Clear Coating, or Single-stage Coating
Impact Resistant Coating Single-Stage Coating, Clear Coating, Underbody Coating, or Truck Bed Liner Coating1151-6 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 Jambing Clear Coating Metallic/Iridescent Topcoat Single-Stage Coating Multi-Color Coatings Multi-Color Coating Multi-Color Multi-Stage Multi-Color Coating Multi-Color Stage System Color Coating & Clear Coating Multi-Color Topcoat Multi-Color Coating

Precoat Primer

Pretreatment Wash Primer Pretreatment Coating

Primer Primer

Primer Sealer Primer Sealer

Primer Surfacer Primer Rubberized Asphaltic Underbody Underbody Coating Single-Stage Metallic/Iridescent Coating Single-Stage Coating Single-Stage Nonmetallic/Noniridescent Topcoat Single-Stage Coating

Solid Color Topcoat Single-Stage Coating Specialty Coatings This generic category has been eliminated an replaced with specific categories for the various coatings previous grouped together and are
adressed below Temporary Protective Coating Temporary Protective Coating
Topcoats Single-Stage Coating

Uniform Finish Blenders Uniform Finish Coating Water Hold-Out Coating Primer Weld-Thru Coatings Primer

(20) “Color Coating” - Any pigmented Coa ting, excluding Adhesion Promoters, Primers, and Multi-color Coatings, that requires a subsequent Clear Coating and which is applied over a Primer, Adhesion Promoter, or Color Coating. Color Coatings include metallic/iridescent Color Coatings. [Definition derived from CARB’s SCM for Automotive Coatings Section 3.12. “Color Coating” was added to the definition to ARB’s comment on D2]

(10) “ Commercial and Non

- Commercial Coating Applications ”

– facilities with Coating operations which include, but are not limited to: autobody repair/paint shops, production autobody paint shops , new car dealer repair/paint shops, fleet operator repair/paint shops, custom

- made car fabrication facilities, truck body

- builders, and
residences. [Deleted as this coating application no longer exists in CARB’s SCM for Automotive Coatings]AVAQMD Rule 1151 1151-7 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 ( 11 21 ) “Elastomeric Materials ” - Coatings which are specifically formulated and applied over coated or uncoated flexible plastic substrates for the purpose of adhesion.

( 12 22 ) “Electrostatic Spray Application ” - a A method of applying Coatings whereby the atomized Coating droplets are charged and subsequently deposited on the substrate by
electrostatic attraction. [Changes made for clarification purposes only]

(23) “Emission Control System” - Any combination of capture systems and control devices used to reduce VOC emissions from Automotive Coating operations. [Changes to definition derived from CARB’s SCM for Automotive Coatings Section3.14]

( 13 24 ) “Exempt Compounds ” - those Those compounds listed in 40 CFR 51.100( s S ) (1)

. [Changes to definition derived from MDAQMD’s Rule 1116 Section (B)(18)]

(14) “ General Topcoat ”

- any type of Topcoat except Metallic/Iridescent Topcoat, and any Topcoat applied as part of a Multistage Topcoat System. [Deleted to synchronize definitions with CARB’s SCM for Automotive Coatings. Definition is no longer necessary]

(25) “Finish” - The Coating of incomplete vehicles, their parts and components, or Mobile Equipment for which the original Coating was not applied from an Original Equipment Manufacturer (OEM) plant Coating Assembly Line. [Derived from MDAQMD’s Rule 1116 Section (B)(19)]

( 15 26 ) “Grams oO f VOC per Liter of Coating Less Water and Less Exempt Compounds (VOC Content) ” - the The weight of VOC per combined volume of VOC and Coating solids and shall be calculated by the following equation:

ES W M ES W S
LoC VOC V V V W W W G

   

 /

Grams of VOC per Liter of Coating, Less W s - W w - W es Water and Less Exempt Compounds = V m - V w - V es1151-8 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 Where:
G VOC/LoC = Grams VOC/L of Coating Less Water and Exempt

W s W S = weight of volatile compounds in grams

W w W W = weight of water in grams

W es W ES = weight of Exempt Compounds in grams

V m V M = volume of material in liters

V w V W = volume of water in liters

V es V ES = volume of Exempt Compounds in liters
[Changes are for clarification purposes only]

( 16 27 ) “Grams of VOC per Liter of Material ” - the The weight of VOC per volume of material as calculated by the following equation:

M ES W S
LoM VOC V W W W G  

 /

W s - W w - W es Grams of VOC per Liter of Material =

V m Where:
G VOC/LoM = Grams VOC/L of Material

W s W S = weight of volatile compounds in grams

W w W W = weight of water in grams

W es W ES = weight of exempt compounds in grams

V m V M = volume of material in liters

[Changes are for clarification purposes only] (17) “Group I Vehicles and Equipment”

- large

- sized Trucks, Buses, and Mobile Equipment. [Deleted to synchronize definitions with CARB’s SCM for Automotive Coatings. Definition is no longer necessary]

(18) “Group II Vehicles”

- Passenger Cars, Small

- Sized Trucks and Vans, Medium

- Sized Trucks and Vans, Motor Homes, and Motorcycles. [Deleted to synchronize definitions with CARB’s SCM for Automotive Coatings. Definition is no longer necessary]

(28) “Group II Exempt Compounds” - Compounds that are restricted because they are either toxic, potentially toxic, upper-atmosphere ozone depleters, or cause other environmental impacts. These compounds are listed as follows:

methylene chloride (dichloromethane) 1,1,1-trichloroethane (methyl chloroform) Trichlorofluoromethane (CFC-11)AVAQMD Rule 1151 1151-9 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 dichlorodifluoromethane (CFC-12) 1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113) 1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114) chloropentafluoroethane (CFC-115) cyclic, branched, or linear, completely methylated siloxanes tetrachloroethylene (perchloroethylene) [Derived from 40 CFR 51.100(S)(1). Compounds removed from the preliminary draft version were removed in response to USEPA’s comment to do so.]

( 19 29 ) “High-Volume, Low-Pressure (HVLP) Spray ” - an E e quipment Permanently Labeled as
such used to apply Coatings by means of a spray gun which is designed to be operated and which is operated between 0.1 and 10 pounds per square inch gauge (psig) air pressure measured dynamically at the center of the air cap and at the air horns. [“Permanetly Labeled” was added to the definition in response to ARB’s comment to do so upon the D2 review]

( 20 ) “ Highway ”

- a way or place of whatever nature, publicly maintained and open to the public for purposes of vehicular travel. Highway includes st ree t.

( 21 30 ) “Impact Resistant Coating ” - any Any Coating applied to a rocker panel for the purpose of chip resistance to road debris.

( 22 31 ) “Metallic/Iridescent Color Coating Topcoat ” - a Topcoat Any Coating which contains iridescent particles, composed of either metal as metallic particles or silicon as mica particles, in excess of five ( 5 ) g/L grams per liter (0.042 lb/gal pounds per gallon ) as applied, where such particles are visible in the dried film. [Changes to definition derived from CARB’s SCM for Automotive Coatings Section 3.18 and for clarification purposes only.]

( 23 ) “Midcoat”

- a semi

- transparent Topcoat which is the middle Topcoat applied as part of
a Three

- Stage Topcoat System. [Deleted as this coating category no longer exists in CARB’s SCM for Automotive Coatings]

( 24 32 ) “Mobile Equipment ”

- Any self

- propelled equipment device which is physically capable of being driven on a highway. may be drawn or is capable of being driven on a Roadway or rails, including but not limited to, trains, railcars, truck bodies, truck trailers, utility bodies, camper shells, mobile cranes, bulldozers, street cleaners, and implements of husbandry or agriculture. Mobile Equipment includes, but is not limited to: construction (mobile crane, bulldozer, concrete mixe r), farming (wheel tractor, plow, pesticide sprayer), and miscellaneous (street cleaners, golf carts, hauling equipment used inside and around an airport, dock, depot, and industrial and commercial plants). [Changes to definition derived from CARB’s SCM for Automotive Coatings Section 3.20 and from SJVUAPCD Rule 4612, section (3.23) and SCAQMD Rule 1151, section (c)(20]1151-10 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 ( 25 ) “ Motor Home ”

- any Motor Vehicle originally designed, or permanently altered, and equipped for human habitation as defined in Section 362 of the California Vehicle
Code. [Deleted as this definition is no longer necessary to comply with CARB’s SCM for Automotive Coatings]

( 26 33 ) “Motor Vehicle ” - a vehicle which is self-propelled and which is physically capable of being driven on a Highwa y. , including, but not limited to cars, trucks, Buses, golf carts, vans, Motorcycles, tanks, and armored personnel carriers. [Changes to definition derived from CARB’s SCM for Automotive Coatings Section 3.20]

( 27 34 ) “Motorcycle ” - any Motor Vehicle other than a tractor having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground and weighing less than 1500 pounds, except that four wheels may be in contact with the ground when two of the wheels are a functional part of a sidecar.

(35) “Multi-Color Coating” - Any Coating that exhibits more than one color in the dried film after a single application, is packaged in a single container, and hides surface defects on areas of heavy use, and which is applied over a Primer or Adhesion Promoter. [Derived from CARB’s SCM for Automotive Coatings Section 3.21]

( 28 36 ) “Multi-Colored Multistage Topcoat System” - A Basecoat/Clearcoat Topcoat System in which the basecoat portion is a Multi-Colored Topcoat “ M ulti

- Colored Topcoat ”

- a Coating which exhibits more than one color when applied, and which is packaged in a single container and applied in a single coat.

( 29 ) “ Multi

- Colored Multistage Topcoat System ”

- a Basecoat/Clearcoat Topcoat System in
which the b asecoat portion is a Multi

- Colored Topcoat.

(37) “Multi-Colored Topcoat” - a Coating which exhibits more than one color when applied, and which is packaged in a single container and applied in a single coat.

( 30 38 ) “Multistage Topcoat System ” - any Any Basecoat/Clearcoat Topcoat System or any Three-Stage Topcoat System, manufactured as a system, and used as specified by the
manufacturer.

( 31 39 ) “Passenger Car ” - any Motor Vehicle designed primarily for transportation of persons and having a design capacity of 12 persons or less.

(40) “Person” - Shall have the same meaning as defined in the California Health and Safety Code §39047. [Derived from CARB’s SCM for Automotive Coatings Section 3.22]

(41) “Permanently Labeled” - Permanent labeling is in the form of an engraving or a plate permanently attached to the equipment.

( 32 42 ) “Pretreatment Coating ” - a A Coating which contains no more than sixteen ( 16 ) percent solids, by weight, and at least one-half (0.5) 1/2

- percent acid, by weight, is used toAVAQMD Rule 1151 1151-11 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 provide surface etching, and is applied directly to bare metal surfaces to provide corrosion resistance and promote adhesion for subsequent Coatings. [Changes are for clarification purposes only]

( 33 43 ) “Primer ” - Any Coating which is labeled and formulated for application to a substrate to provide 1) a bond between the substrate and subsequent coats, 2) corrosion resistance, 3) a smooth substrate surface, or 4) resistance to penetration of subsequent coats, and on which a subsequent Coating is applied. Primers may be pigmented. a Coating applied for purposes of corrosion resistance or adhesion of subsequent Coatings. [Changes to definition derived from CARB’s SCM for Automotive Coatings Section3.24]

( 34 44 ) “Primer Sealer ” - Any a Coating which is labeled and formulated for application applied prior to the application of a Topcoat Color Coating for the purpose of color uniformity, or to promote the ability of an underlying Coating to resist penetration by the Topcoat Color Coating

. [Changes to definition derived from CARB’s SCM for Automotive Coatings Section3.25]

( 35 45 ) “Primer Surfacer ” - a A Coating applied for the purpose of corrosion resistance or adhesion, and which promotes a uniform surface by filling in surface imperfections.

(46) “Reducer” - Any volatile liquid used to reduce the viscosity of the Coating, but not used for Cleaning Operations. This liquid may be solvents, diluents, or both, and may also
be referred to as a thinner. [Derived from MDAQMD’s Rule1116, Section (B)(32). Changes to this definition made in response to ARB’s comment on D2. Additional changes added to distinguish Reducer solvents from cleaning solvents added in response to ACA comments of D2.]

(47) “Refinishing” - Any Coating of Motor Vehicles, their Associated Parts and Components, or Mobile Equipment, including partial body collision repairs, for the purpose of protection or beautification and which is subsequent to the original Coating applied at an Original Equipment Manufacturing (OEM) plant Coating Assembly Line. [Derived from MDAQMD’s Rule1116, Section (B)(33)]

(48) “Roadway” - A way or place used for purposes of vehicular travel. [definition was changed from “Highway” to “Roadway” and modified to ensure the definition of “Mobile Equipment” is not affected by the use of roads.]

( 36 49 ) “Rocker Panel ” - the The panel area of a Motor Vehicle which is no more than ten inches from the bottom of a door, quarter panel or fender.

( 37 50 ) “Rubberized Asphaltic Underbody Coating ” - a A Coating applied to wheel wells, the inside of door panels or fenders, the underside of a trunk or hood, or the underside of the Motor Vehicle itself, for the purpose of sound deadening or protection.

(51) Single-Stage Coating” – Any pigmente d coating, excluding Primers and Multi-Color coatings, labeled and formulated for application without a subsequent clear coat.1151-12 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 Single-stage coatings include single-stage metallic/iridescent Coatings. [Added to conform with SCM, section 3.26]

( 38 52 ) “Solvent Cleaning Operations ” - the The removal of loosely held uncured adhesives, uncured inks, uncured Coatings, and contaminants which include, but are not limited to, dirt, soil, and grease from parts, products, tools, machinery, equipment, and general work areas. Each distinct method of cleaning in a cleaning process which consists of a series of cleaning methods shall constitute a separate Solvent Cleaning Operation.

( 39 53 ) “Specialty Coating ” - A a ny of the following Coatings: Adhesion Promoters, Uniform Finish Blenders, Elastomeric Materials, An ti-Glare Safety Coatings, Impact ResistantCoatings, Rubberized Asphaltic Underbody Coatings, Water Hold-Out Coatings, WeldThru Coatings, and Bright Metal Trim Repair Coatings.

( 40 54 ) “Spot Repair s ” - Repair of an area on a motor vehicle, piece or mobile equipment, or associated parts or components of less than an entire panel. repairs to Motor Vehicles in which the damaged area to be repaired is limited to only a portion of any given panel so that an entire panel need not be repaired. [Change in definition was made in response to comment from the American Coatings Association requesting this language to better reflect the rationale behind spot repair.]]

(55) “Stripping” - The use of solvent to remove material such as cured adhesives, cured inks, cured or dried paint, cured or dried paint residue, or Temporary Protective Coatings. [Derived from SJVUAPCD Rule 4612, section (3.36)]

( 41 56 ) “Stencil Coating ” - an An ink or a pigmented Coating which is rolled or brushed onto a template or a stamp in order to add identifying letters, symbols, and/or numbers to Motor Vehicles, Mobile Equipment, or their parts and components.

(57) “Targeted HAP Compounds”- The Hazardous Air Pollutant (HAP) compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) targeted by 40 CFR 63 Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellane ous Surface Coating Operations at Area
Sources. [Definition added to comply with 40 CFR 60 Subpart 6H]

(42) “Three

- Stage Topcoat System”

- a Topcoat system com posed of a Basecoat portion, a Midcoat portion and a transparent Clearcoat portion. The VOC content of a Three

Stage Topcoat System shall be calculated according to the following formula:

VOC bc + VOC mc + 2 VOC cc VOC ms = 4AVAQMD Rule 1151 1151-13 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 Where:

VOC ms = the composite VOC content, less water and less exempt compounds, to be used for compliance determination under the Multistage Topcoat System Coating category.
VOC bc = the VOC content, less water and less exempt compounds as applie d, of any given Basecoat.
VOC
mc = the VOC content, less water and less exempt compounds as applied, of any given Midcoat.
2 VOC
cc = two times the VOC content, less water and less exempt compounds as applied, of any given Clearcoat.

(58) “Temporary Protective Coatings” - Any Coating which is labeled and formulated for the purpose of temporarily protecting areas form overspray or mechanical damage. [Derived from CARB’s SCM for Automotive Coatings Section3.29]

( 43 59 ) “Topcoat ”

- – Any Coating applied over a Primer, Primer System or an original OEM
Finish a Coating applied over any Coating, for the purpose of appearance, identification, or protection.

[The definition of “Touch-up” was deleted from this rule as requested by ARB upon their review of D2]

( 44 ) “ T ouch

- Up Coating ”

- a Coating applied by brush, air

- brush, or non

- refillable aerosol can to cover minor surface damage and dispensed in containers of no more than eight (8) ounces.

( 45 60 ) “Transfer Efficiency ” - T t he ratio of the weight of Coating solids deposited on an object to the total weight of Coating solids used in a Coating application step, expressed as a
percentage.

( 46 61 ) “Truck ” - A a Motor Vehicle designed, used, or maintained primarily for the transportation of property.

(a) “Large-Sized Truck ” - a A Truck having a manufacturer's gross vehicle weight rating of more than 8600 pounds.

(b) “Medium-Sized Truck ” - a A Truck having a manufacturer's gross vehicle weight of 6001 to 8600 pounds.

(c) “Small-Sized Truck” - any Any Motor Vehicle having a manufacturer's gross vehicle weight rating at 6000 pounds or less and which is designed primarily for the purposes of transportation of property or is a derivative of such vehicle, or is available with special features enabli ng on-street or off-highway operation and

use.1151-14 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (62) “Truck Bed Liner Coating” - Any Coating, excluding Clear, Color, Multi-color, and Single-stage Coatings, labeled and formulated for application to a truck bed to protect it
from surface abrasion. [Derived from CARB’s SCM for Automotive Coatings Section3.31. “Clear” was added in this definition upon the request of ARB of D2 review.]

(63) “Underbody Coating” - Any Coating labele d and formulated for application to wheel wells, the inside of door panels or fenders, the underside of a trunk or hood, or the
underside of the motor vehicle. [Derived from CARB’s SCM for Automotive Coatings Section3.32]

( 47 64 ) “Uniform Finish Blenders ”

- Any Coating labeled and formulated for application s which are applied in to the area around a Spot Repairs for the purpose of blending a repaired area’s color or clear coat to match the appearance of of an adjacent area’s existing Coating. paint overspray area of a repaired Topcoat to match the appearance of an adjacent existing Topcoat. On and after 07/01/12 this Coating Category will be referred to as Uniform Finish Coating. [The changes in this definition were made in response to ARB’s comment of D2 to limit confusion between the definition of “ Uniform Finish Blenders” and “Uniform Finish Coating”.]

(65) “Uniform Finish Coating”- Any Coating la beled and formulated for application to the area around a Spot Repair for the purpose of blending a repaired area’s color or clear coat to match the appearance of an adjacent area’s existing Coating. Prior to 07/01/12 this Coating Category may be referred to as Uniform Finish Blenders. [The changes in this definition were made in response to ARB’s comment of D2 to limit confusion between the definition of “ Uniform Finish Blenders” and “Uniform Finish Coating”.]

[Changes to definition derived from CARB’s SCM for Automotive Coatings, Section 3.33]

( 48 66 ) “Van ” - a closed Truck for carrying property or persons.

(a) “Medium-Sized Van ” - a A Van having a manufacturer's gross vehicle weight rating of 6001 to 8600 pounds.

(b) “Small-Sized Van ” - A a Van having a manufacturer's gross vehicle weight rating at 6000 pounds or less and which is designed primarily for purposes of transportation of property and/or persons.

( 49 67 ) “Vehicle ” - a device by which any person or property may be propelled, moved, or drawn upon a Highway Roadway , excepting a device moved exclusively by human power or used exclusively upon stationary rails or tracks.

(68) “VOC Actual” - This definition is the same as the definition of Grams of VOC per Liter of Material as listed under subsection (B)(27). [Definition derived from CARB’s SCM for Automotive Coatings, Section 3.36.2]AVAQMD Rule 1151 1151-15 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (69) “VOC Regulatory” - This definition is th e same as the definition of Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds as listed under subsection (B)(26). [Definition derived from CARB’s SCM for Automotive Coatings, Section 3.36.1]

( 50 70 ) “Volatile Organic Compound (VOC) ”

- – A a ny volatile compound containing the element carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and Exempt Compounds.

(51) “VOC per Volume of Applied Solids”

–the weight of VOC per volume of applied Coating solids, as calculated by the following equation:

Lbs. VOC per WPG * (100

- %NV
w - %NOV

w - %EV
w )
Gallon of Solids =

______________________________________________ %NV
v Where:
WPG = weight of a gallon of Coating in pounds
%NVw = percent by weight of non

- volatile compounds
%NOV

w = percent by weight of non

- organic volatil e compounds

%Evw = percent by weight of Exempt Compounds
%NVv = percent by volume of non

- volatile compounds [Definition deleted as no longer necessary to conform with CARB’s SCM for Automotive Coatings]

( 52 71 ) “Water Hold-Out Coating ” - a A Coating applied to the interior cavity areas of doors, quarterpanels and rocker panels for the purpose of corrosion resistance to prolonged
water exposure.

( 53 72 ) “Weld-Thru Coating ” - a A Coating applied to metal immediately prior to welding to provide corrosion resistance.



### (C) Requirements

(1) VOC Content of Coatings

(a) Effective on the dates specified, a person shall not apply Coating to a Motor Vehicle, Mobile Equipment, or Associated Parts or Components, that has a
VOC content in excess of the limits contained in Table 1 and Table 2 of this subsection except as provided in Section (C)(3)(a) or (b). A person shall not apply a Coating to Group I Vehicles and Equipment, and Group II Vehicles, or their parts and components, which has a VOC content which exceeds the limits contained in subparagraphs (C)(1)(a) and (C)(1)(b). Compliance with the VOC1151-16 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 limits shall be based on VOC content, including any VOC material added to the original Coating supplied by the manufacturer, less water and Exempt Compounds, as applied to the Vehicle, Mobile Equipment, or parts and
components. [Changes derived from CARB’s SCM for Automotive Coatings, Section 4.1]

(i) Group I Vehicles and Equipment
1. A person who applies Coatings to Group I Vehicles and Equipment, or their parts or compone nts, shall not apply a Coating which has a VOC content in excess of the limits in Table
1. TABLE 1 Table 1 - Coating Categories and VOC Limits

VOC Re g ulator y Limit, as applied, in g rams per Liter (pounds per gallon)

Coating Categories Effective on and after 05/01/13

Adhesion Promoter 540 (4.5)
Clear Coating 250 (2.1)
Color Coating 420 (3.5)
Multi-color Coating 680 (5.7)
Pretreatment Coating 660 (5.5)

Primer 250 (2.1)

Primer Sealer 250 (2.1)
Single-stage Coating 340 (2.8)
Temporary Protective Coating 60 (0.5)
Truck Bed Liner Coating 310 (2.6)
Underbody Coating 430 (3.6)
Uniform Finish Coating 540 (4.5)
Any Other Coating Type 250 (2.1)[Changes derived from CARB’s SCM for Automotive Coatings, Section 4.1. The extended Singlestage Coating VOC compliance date was removed in response ARB’s comment to do so upon review of D2. The Vinyl Interior Coating category was also deleted in response to ARB’s comment for removal upon review of D2]

COATING VOC LIMITS Grams per Liter of Coating,

Less W ater and Exempt Compounds on and after January 1, 1997 g/L lb/galAVAQMD Rule 1151 1151-17 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 COATING VOC LIMITS Grams per Liter of Coating,

Less W ater and Exempt Compounds on and after January 1, 1997
Pretreatment 780 6.5 Primer/Primer Surfacer/ Primer Sealer 250 2.1

Topcoats General 340 2.8 Metallic/Iridescent 340 2.8 Multi

- Colored 680 5.7 Multistage 340 2.8 Specialty Coating 840 7.0 [Changes derived from CARB’s SCM for Automotive Coatings, Section 4.1]

(ii) Group II Vehicles
1. A person who applies Coatings to Group II Vehicles, or their parts or components, except the application of Multistage Topcoat Systems to Motor Hom es as part of their original production, shall not apply a Coating which has a VOC content
in excess of the limits in Table 2.

TABLE 2

COATING 

### VOC LIMITS Grams per Liter of Coating, Less Water and Exempt Compounds On and After July 20, 1999 On and Afte r July 1,
2000 g/L lb/gal g/L lb/gal

Pretreatment 780 6.5 780 6.5

Primer/Primer Surfacer 250 2.1 250 2.1

Primer Sealer 340 2.8 340 2.8 Topcoats 

## General 420 3.5 420 3.5

Metallic/Iridescent 420 3.5 420 3.5

Multi

- Colored 680 5.7 680 5.7

Multista ge System 540 4.5 420 3.5

Multi

- Colored Multistage 420 3.5 420 3.5

Specialty Coating 840 7.0 840 7.0

2. A person who applies Coatings to Motor Homes and/or their parts and components as part of their original production shall1151-18 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 not apply any Multistage T opcoat System that results in VOC per Volume of Applied Solids in excess of 15.0 lb/gal. Table 2 - Coating Categories and VOC Limits

VOC Regulatory Limit, as applied, in grams per Liter (pounds per gallon)

Coating Categories Group 1* Vehicles prior to
05/01/13 Group 2** vehicles prior
to 05/01/13

Pretreatment Wash Primer 780 (6.5) 780 (6.5)
Primer/Primer Surfacer/ Primer
Sealer 250 (2.1) 250 (2.1)

Primer Sealer 250 (2.1) 340 (2.8) Topcoat

General 340 (2.8) 420 (3.5)

Metallic/Iridescent 340 (2.8) 420 (3.5)

Multi-Colored 680 (5.7) 680 (5.7) Multistage 340 (2.8) 420 (3.5) Specialty Coatings 840 (7.0) 840 (7.0) *Group 1 Vehicles are public transit buses and mobile equipment including but not limited to: truck bodies, truck trailers, utility bodies, camper shells, mobile cranes, bulldozers, street cleaners, golf carts, and implements of husbandry, where color match is not required. **Group 2 Vehicles are passenger cars; large/heavy duty truck cabs and chassis with a manufacturer's gross vehicle weight over 10,000 pounds; light a nd medium duty trucks and vans having a manufacturer's gross vehicle weight rating of 10,000 pounds or less; and motorcycles; and Group 1 Vehicles where color match is required. [Table 2 inserted to maintain current Rule lim its until the limits of CARB’s SCM for Automotive Coatings come in to effect]

(b) Compliance with the VOC limits shall be based on VOC Content, including any VOC material added to the original coating supplied by the manufacturer, less water and Exempt Compounds, as applied to the Motor Vehicle, Mobile Equipment, or Associated Parts or Components (please, refer to subsection (B)(26) for the calculation of VOC Content). [Derived from SCAQMD Rule 1151, section (d)(1). Additional reference to (B)(26) was added in response to USEPA’s comment on the preliminary draft suggesting to add reference.]

(2) Most Restrictive VOC Limit

(a) If anywhere on the container of any Automotive Coating, or any label or sticker affixed to the container, or in any sales, advertising, or technical literature, any representation is made that indicates that the Coating meets the definition of, or is recommended for use of, more than one of the Coating categories listed in subsection (C)(1)(a) and (b), then the lowest applicable VOC content limit inAVAQMD Rule 1151 1151-19 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 Table 1 and Table 2 shall apply. [Derived from CARB’s SCM for Automotive Coatings, Section 4.2].

(3) Alternative Compliance

(a) Emission Control System

A person may comply with the provisions of section (C)(1) by using an approved Emission Control System consisting of collection and control devices, that is approved, in writing, by the APCO for reducing emissions of VOC. The APCO shall approve such Emission Control Systems only if the Emission Control System demonstrates a control efficiency of at least 85 percent. The required efficiency of an Emission Contro l System at which an equivalent or greater level of VOC emission reduction will be achieved shall be calculated by the following equation: [The reference to achieving a control efficiency of at least 85% has been included specifically in the second draft due to USEPA’s comment requesting the specific limit be designated in rule language in this section.]

100

1 1

1 , ,

, 

     

 

     

 

  

   

 

  

   

 

       

        





 



## D VOC

D VOC

VOC

VOC

c LWc Max n Max

LWn

Max LWn

LWc CE

Where: CE = Control Efficiency, percent
VOC LWc = VOC Limit of Rule 1116, less water and less Exempt Compounds, pursuant to Section C.1.
VOC LWn,Max = Maximum VOC content of non-compliant Automotive Coating used in conjunction with a control device, less water and Exempt Compounds.

D n,Max = Density of VOC solvent, Reducer, or thinner contained in the non-compliant Automotive Coating containing the maximum VOC.

D c = Density of corresponding VOC solvent, Reducer, or thinner used in the compliant Automotive Coating system = 880g/L.

(b) Alternative Emission Control Plan1151-20 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 A person may comply with the provisions of paragraph (C)(1)(a) by means of an Alternative Emissions Control Plan, pursuant to Rule 108 – Alternative Emissions Control Plans. [Derived from SCAQMD Rule 1151, section (d)(4)(A) and CARB’s Suggested Control Measure for Automotive Coatings section (4.3)] (4) Prohibited Compounds

(a) A Person shall not manufacture, sell, offer for sa le, distribute for use in the District, or apply any Automotive Coating which contains any Group II Exempt Compounds, as defined in subsection (B)(28). [Derived from 40 CFR 51.100(s)(1). Compounds removed from the preliminary draft version were removed in response to USEPA’s comment to do so.] ( 2 5 ) Carcinogenic Materials

(a) A person shall not manufacture apply Automotive Coatings in which cadmium or hexavalent chromium was introduced as a pigment or as an agent to impart any property or characteristic to the Coatings during manufacturing, distribution, or use of the applicable Coatings

. Coatings as defined by the Air Toxic Control Measure (ATCM) for Emissions of Hexavalent Chromium and Cadmium from Motor Vehicle and Mobile Equipment Coatings , Title 17 CCR,
section 93112. [Derived from SCAQMD Rule 1151, section (d)(6)and ATCM: Title 17 CCR, section 93112].

( 3 6 ) Transfer Efficiency Application Methods [Change made for clarification purposes only]

(a) Except for Underbody Coatings, graphic arts operations, Truck Bed Liner Coatings, or any Coating use of less than one (1.0) fluid ounce (29.6 milliliters),

no A person shall not apply any Coating s except to Motor Vehicles or Mobile Equipment or their Associated Parts and Components unless by the use of one of the following methods: [Changes added in response to EPA’s comment to include the exception of Underbody Coatings, graphic arts, Truck Bed Liner Coatings and Coating use of less than one fluid ounce.]

(i) Brush, dip, or roller; or, [Added to conform with SCM, section 4.7.1] (ii) electrostatic Electrostatic A a pplication equipment, operated in accordance with the manufacturer’s recommendations and in compliance with permit conditions;

, or , (iii) (ii) High-Volume, Low-Pressure (HVLP) Spray, or operated in accordance with the manufacturer’s recommendations and in compliance with permit conditions; or, a. No Person shall sell or offer for sale, for Automotive Refinishing use within the District, any HVLP spray gun without a permanent marking denoting the maximum inlet air pressure in pounds per square inch gauge (psig) at which the gun will operate within the parameters specified in Section (B)(29). b. If an Automotive Refinishing gun is not Permanently Labeled, the operator must demonstrate that the gun meets the HVLP definition inAVAQMD Rule 1151 1151-21 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 Section (B)(29) in design and use. A satisfactory demonstration must be based on the manufacturer’s published technical material on the design of the gun and by a demonstration of the operation for the gun using an air pressure tip gauge designed specifically for the gun in use. [These subsections were added in response to EPA’s comment to do so from the review of Draft 2]

(i v ii ) Any other Coating application which has been demonstrated to the
satisfaction of the APCO to be capable of achieving a Transfer Efficiency equivalent to, or higher than, the application methods listed in subsections (C)(6)(a)(i) and (C)(6)(a)(ii) above, but not less than 65 percent, as per subsections (G)(2)(e) and (G)(2)(k), such other Coating application methods as are demonstrated, in accordance with the provisions of subsection (F)(1)(e), to be capable of achieving equivalent or better transfer efficiency than the Coating application method listed in subsection (C)(3)(a)(ii), and for which written approval of the Air
Pollution Control Officer APCO has been obtained. [Changes derived from CARB’s SCM for Automotive coatings, Section 4.7 and MDAQMD’s Rule 1116, Section (C)(6)(a)]

( b) A person shall not apply Coatings by any of the methods listed in subparagra ph (C)(3)(a) unless the Coating is applied with properly operating equipment, operated according to procedures recommended by the manufacturer. [ Deleted as this language as been reworded in the above subsections]

( 4 7 ) Surface Preparation and Cleaning Operations Solvent Cleaning Operations; Storage and Disposal of VOC

- containing Materials [Change incorporated for clarification purposes only]

(a) Solvent cleaning of application equipment, parts, products, tools, machinery, equipment, general work areas, and t he storage and disposal of VOC

- containing materials used in cleaning operations shall be carried out pursuant to Rule 1171

- Solvent Cleaning Operations.

(a) The requirements of this subsection shall apply to any Person using solvent for Surface Preparation and Cleaning Operations.

(i) Any Person shall not use an organic compound(s), or mixture thereof, (excluding Exempt Compounds) for Surface Preparation and Cleaning Operations with a VOC content in ex cess of twenty-five (25) grams per liter (0.21 pounds per gallon) of material. 1. Cleaning with aerosol solvent products shall not be subject to the provisions of subsection (C)(7)(a) if 160 fluid ounces or less of aerosol solvent products are used per day, per facility. [Aerosol solvent product1151-22 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 exemption added in response to ACA comment of review of D2. This exemption is from SCAQMD Rule 1171]. (ii) Any Person shall use closed, non-absorbent containers for the storage or disposal of any applicator (includi ng brushes, swabs, cloth or paper) used for solvent Surface Preparation and Cleaning Operations. (iii) Any Person shall store all Automotive Coatings, Coating components, and fresh or spent solvent in vapor tight and closed containers, except while adding or removing them from the containers. [This subsection was expanded to include all automotive coatings and components in response to EPA’s comment to do so upon review of draft 2] (iv) Any Person shall not use organic compounds for the Cleaning Operations of spray equipment including paint liners unless an enclosed system is used for Cleaning Operations. The system shall enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining procedures. Equipment used shall minimize the evaporation of organic compounds to the atmosphere. [Changes made to conform with the requirements of CARB’s SCM for Automotive Coatings. The old solvent VOC requirements referenced in AVAQMD Rule 1171 are less stringent than the SCM, therefore, the reference in this rule has been removed.]

(b) Effective May 1, 2013, no Person shall possess at any Automotive Refinishing Facility, any solvent used for Surface Preparation and Cleaning Operations with a VOC content that does not comply with the requirements in subsection (C)(7)(a)(i). [Changes made to conform to the requirements of CARB’s SCM for Automotive Coatings section 4.4. The old solvent VOC requirements referenced in AVAQMD Rule 1171 are less stringent than the SCM, therefore, the reference in this rule has been removed.]

(5) Approved Emission C ontrol System

(a) A person may comply with the provisions of subsection (C)(1)(a), by using an approved emission control system, consisting of collection and control devices, which is approved, in writing, by the Air Pollution Control Officer for reducing emissions of VOC. The Air Pollution Control Officer shall approve such emission control system only if the VOC emissions resulting from the use of

non

- compliant Coatings will be reduced to a level equivalent to or lower than
that which would have been ach ieved by the compliance with the terms of paragraph (C)(1)(a). The required efficiency of an emission control system at which an equivalent or greater level of VOC emission reduction will be achieved shall be calculated by the following equation: [This section has been moved to Section (C)(3)]AVAQMD Rule 1151 1151-23 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (VOC LWc ) 1

- (VOC LWn,Max /D n,Max )

C.E. = 1

-

_____________ X

_______________________ X 100
(VOC LWn,Max ) 1

- (VOC LWc /D

c )

Where:

C.E. = Control Efficiency, percent
VOC LWc = VOC Limit of Rule 1151, less water and less Exempt Compounds, pursuant to paragraph (c)(1).
VOC LWn,Max = Maximum VOC content of non

- compliant Coating used in conjunction with a control device, less water and Exempt Compounds.

D n,Max = Density of VOC solvent, reducer, or thinner
contained in the non

- compliant Coating containing
the maximum VOC.

D

c = Density of corresponding VOC solvent, reducer, or thinner used in the compliant Coating system =
880 g/L.

(6) Alternative Emission Control Plan [This section has been moved to Section (C)(3)]

(a) A person may comply with the provisions of paragraph (c)(1) by means of an Alternative Emission Control Plan (AECP), pursuant to Rule 108.

( 7 8 ) Prohibition of Possession, Specification and Sale

(a) No p erson shall solicit from, or require a ny other p erson to use in the District any Coating which, when applied as supplied or thinned or reduced according to the manufacturer's recommendation for application, does not meet the applicable VOC limits required by subsection (C)(1)(a) for the specif ic application, or does
not meet the requirements of subsection (C)(2)(a). [Deletion made here as these requirements have been re-worded and expanded to comply with CARB’s SCM for Automotive Coatings Sections 4.4, 4.5, 4.6, and 5.6.]

( a b ) No P p erson subject to this rule shall posses any Automotive Coating that is not in compliance with the requirements of subsection (C)(1), unless one or more of the following conditions apply: shall offer for sale, sell, or distribute for use in the District any Coating whi ch, when applied as supplied or thinned or reduced according to the manufacturer's recommendation for application, does not meet the applicable VOC limits required by subsection (C)(1)(a) for the specific application, or does not meet the requirements of s ubsection (C)(2).1151-24 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (i) The Coating is located at a facility that utilizes an approved Emission Control System pursuant to subsection (C)(3)(a), and the Coating meets the limits specified in permit conditions. (ii) The Coating is located at a facility that operates in compliance with an approved Alternative Emissions Control Plan pursuant to subsection (C)(3)(b), and the Coating is specified in the plan. (iii) The Coating is located at a training center and the Coating is used for educational purposes, provided that the VOC emissions from Coatings not meeting VOC limits of section (C)(1) do not exceed twelve (12) pounds per day. (iv) The Coating is located at a prototype Motor Vehicle manufacturing facility and the Coating is supplied by an assembly-line Motor Vehicle manufacturer for use in the Refinishing of a prototype Motor Vehicle, provided that the VOC emissions from Coatings not meeting the VOC limits of section (C)(1) do not exceed twenty-one (21) pounds per day and 930 pounds in any one calendar year. [Changes derived from CARB’s SCM for Automotive Coatings section 4.4 and SJVUAPCD Rule 4612, section (5.5)]

( b c ) No person shall solicit from, orrequire any other Person to use

, offer for sale to, sell to, or distribute to any other person for use in the District any Automotive Coating or solvent application equipment which, when applied as supplied or thinned or reduced according to the manufacturer’s recommendation for application, which does not meet the requirements of subsection (C)(3)(a). does
not meet the:

(i) Applicable VOC limits required by subsection (C)(1) for that specific application unless: a. The Coating is located at a Automotive Refinishing Facility that utilizes an approved Emission Control System pursuant to subsection (C)(3)(a), and the Coating meets the limits specified in permit conditions. b. The Coating is specifically exempt pursuant to section (D) of this
rule. [Changes derived from CARB’s SCM for Automotive Coatings sections4.5 and 4.6] (ii) Applicable VOC limits for solvent for Surface Preparation and Cleanup Operations pursuant to section (C)(7). [Subsection added in response to EPA’s comment to do so upon review of Draft 2 to include solvents in this section.]

(c) No Person shall manufacture, blend, supply, repackage for sale, offer for sale, sell, or distribute for use in the District any Automotive Coating which, when applied as supplied or thinned or reduced according to the manufacturer’s recommendation for application, does not meet the [Language was added toAVAQMD Rule 1151 1151-25 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 inclue, “manufacture, blend, supply, repackage for sale” in response to EPA’s comment to do so upon review of Draft 2] :

(i) Applicable VOC limits required by subsection (C)(1) for the specific application, unless: a. The Coating is located at an Automotive Refinishing Facility that utilizes an approved Emission Control System pursuant to subsection (C)(3)(a), and the Coating meets the limits specified in permit conditions. b. The Coating is specifically exempt under section (D) of this rule. c. The Person that offers for sale or distributes the Coating keeps the following records for at least five (5) years and makes them available to the APCO upon request, the following information: 1. Coating name and manufacturer; 2. Application method; 3. Automotive Coating Category and mix ratio specific to the Coating; 4. VOC content of Coating; 5. Documentation that the material is a Coating; 6. Current manufacturer specification sheets, material safety data sheets (MSDS), technical data sheets, or air qualitydata sheets, which list the VOC content of each ready-tospray Coating (based on the manufacturer’s stated mix ratio), Automotive Coating Components, and VOC content of each solvent; 7. Purchase records identifying the Automotive Coating category, name, and volume of Coatings; and, 8. The name and address of the Person purchasing the Coating, a statement of the basis the purchase will comply with this paragraph, including if use is for outside the District, and acknowledgement by the purchaser that this
statement is correct. [Changes derived from SJVUAPCD Rule 4612, section (5.7) and CARB’s SCM for Automotive Coatings, section 4.5 and 4.6]

(ii) Requirements of subsections (C)(4) and (C)(5). [Changes derived from SJVUAPCD Rule 4612, section (5.7) and CARB’s SCM for Automotive Coatings, section 4.5 and 4.6

(d) No P p erson shall solicit from, require, offer for sale to , sell to , or distribute to any other Person for the use in the District any Automotive Coating application equipment that does not meet the requirements of subsection (C)(6). an HVLP spray gun unless the person offering for sale, selling, or distributing the HVLP spray gun provides accurate information to the spray gun recipient on the1151-26 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 maximum inlet air pressure to the spray gun which would result in a maximum 10 poun ds per square inch gauge air pressure measured dynamically at the center of the air cap and the air horns. The information shall be permanently marked on the gun, or provided on the company's letterhead or in the form of technical literature which clearly identifies the spray gun manufacturer, the salesperson, or the distributor. [Changes made for simplification and clarification purposes only]

(e) The requirements of subsections (C)( 7 1 ) , (C)(2), and (C)(3) (a)

- (d) shall apply to all written or oral agreements executed and entered into under the terms of
which a n Automotive Coating or a Coating application equipment shall be used at any location within the District. [Changes made for clarification purposes only].



### (D) Exemptions

(1) The provisions of subsect ions (C)(1)(a) and (C)(4) of this rule shall not apply to:

(a) Touch

- Up Coatings. [Deleted as this is addressed in section (D)(1)(e) below]

(a) Any Coating applied to Motor Vehicle or Mobile Equipment, or their Associated Parts and Components, during manufacture on an Assembly Line.

(b) Any Automotive Coating that is offered for sale, sold, or manufactured for use outside of the District or for shipment to other manufacturers for reformulation or repackaging. [Change derived from CARB’s SCM for Automotive Coatings, section 2.2.1]

( b c ) Any Stencil Coating s Product

.

(d) Any Aerosol Coating Product. [Change derived from CARB’s SCM for Automotive Coatings, section 2.2.2]

(e) Any Automotive Coating that is sold, supplied, or offered for sale in one-half (0.5) fluid ounce or smaller containers. [Change derived from CARB’s SCM for Automotive Coatings, section 2.2.3]

(2) The prohibitions specified in subsection (C)(7) shall not apply to Coatings or spray equipment which will be used solely outside of the District. [Deleted as it has been moved to subsection (D)(1)(b) above]AVAQMD Rule 1151 1151-27 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 ( 3 2 ) The prohibitions specified in subsections (C)( 7 8 ) (a) or (b) shall not apply to persons offering for sale to, selling to, distributi ng to, or requiring other persons who are operating an approved emission Emission control Control system System under subsection (C)( 5 3 ) (a) , or complying under subsection (C)( 6 3 ) (b) , or operating pursuant to subsection (D)( 4 3 ).

( 4 3 ) The requirements of subsection (C)(1)(a) shall not apply to Coatings applied for educational purposes at Coating training centers, which are owned and operated by Coating manufacturers, provided that the VOC emissions emitted at a Coating training center from Coatings not complying with subsection (C)(1)(a) do not exceed twelve (12) pounds per day.

(4) The requirements of subsection (C)(1) shall not apply to Coatings located at a prototype Motor Vehicle manufacturing facility and the Coating is supplied by an assembly-line
Motor Vehicle manufacturer for use in the Re finishing of a prototype Motor Vehicle, provided that the VOC emissions from Coati ngs not meeting the VOC limits of section (C)(1) do not exceed twenty-one (21) pounds per day and 930 pounds in any one
calendar [Changes made to reconcile this subsection with subsection (C)(8)(iv) in response to EPA’s comment to do so upon review of Draft 2]

(5) Any facility or Person classified as exempt or claiming to be exempt under this section, (D), shall meet the record keeping requirements of this rule so as to be able to prove the exemption status. [Added for enforcement purposes]

(6) Rule 442 Applicability

(a) Any Coating, Coating operation, or facility which is exempt from all or a portion of the VOC limits of this rule sh all comply with the provisions of Rule 442 if applicable. [Moved from Section G. The words, “if applicable” were added to clarify that exempt coatings/solvents from this rule may apply to Rule 442. This was made in response to USEPA comment requesting clarification]

(5) The provisions of this rule shall not apply to Aerosol Coating Products. [Requirement has been moved to subsection (D)(1)(d)

(6) For Spot Repairs on Group I Vehicles and Equipment, the Grams of VOC per Liter of Coating Less Water and Exempt Compounds limits for Metallic/Iridescent and Multistage Topcoa ts are 3.5 lb/gal. [Deleted as VOC limits for Spot Repairs are the same as VOC limits for any Automotive Refinishing repair]1151-28 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 

### (E) Administrative Requirements [Section added to conform with CARB’s SCM for Automotive Coatings, section 5]

(1) Manufacturer’s Compliance Statement Requirement [Section added to conform with CARB’s SCM for Automotive Coatings, section 5.1]

(a) For each individual Automotive Coating, Automotive Coating Component, and ready-to-spray mixture (based on the manufacturers stated mix ratio), the manufacturer and/or repackager shall include the following information on a product data sheet, or an equivalent medium: [“Repackagers” was added to this subsection at the request of CARB upon review of Draft 2. Solvents was also included in the Manufacturer’s Complinace Statement Requirement upon the request of CARB.]

(i) The VOC Actual and the VOC Regulatory for Coatings (in grams per liter). (ii) The weight percentage of volatiles, water, and Exempt Compounds. (iii) The volume percentage of water and Exempt Compounds. (iv) The density of the material (in grams per liter). (v) The weight percentage of all Targeted HAP Compounds. [Section added to conform with CARB’s SCM for Automotive Coatings, section 5.1.1 to 5.1.3. HAP requirement to ensure compliance with NESHAP 6H] (b) For each solvent used in Solvent Cleaning Operations, the manufacturer and/or repackager shall include the following information on a product data sheet, or an equivalent medium: [“Solvent” was also included in the Manufacturer’s Compliance Statement Requirement upon the request of CARB. In response to the American Coating Association, the solvent section was separated out to only include the following requirement]

(i) The VOC Actual and the VOC Regulatory for Coatings (in grams per liter).

(2) Manufacturer’s Labeling Requirements [Section added to conform with CARB’s SCM for Automotive Coatings, section 5.2]

(a) The manufacturer and/or repackager of Automobile Coatings or Automotive Coating Components shall include, on all containers, the applicable use Coating Category(ies), and the VOC Actual and the VOC Regulatory for Coatings, as supplied (in grams per liter). [Section added to conform with CARB’s SCM for Automotive Coatings, section 5.2.1]

(b) The manufacturer and/or repackager of solvents subject to this rule shall include on all containers the VOC content for solvents, as supplied (in grams per liter)AVAQMD Rule 1151 1151-29 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 [Section added to conform with CARB’s SCM for Automotive Coatings, section 5.2.2]

[“Repackager” was added to each of these subsections in addition to “manufacturer” in response to ARB’s comment on D2]



### ( E F ) Record Keeping Requirements

(1) Record Keeping for VOC Emissions

(a) Records of Coating usage shall be maintained pursuant to Rule 109. [This section has been removed and specific requirements from CARB’s SCM for Automotive Coatings sections 5.4, 5.5, and 5.6 have been added. The current Rule 109 standards are in conflict with the SCM requirements, thus this reference has been removed.]

(2) Record Keeping for Emission Control System s

(a) Any person using an emission control system as a means of complying with the provisions of subsection (C)(1)(a) shall maintain daily records of key system operating and maintenance procedures which will demonstrate continuous operation and compliance of the emission control system during periods of emission producing activities. Key system operating parameters are those necessary to ensure compliance with VOC limits. The parameters include, but are not limited to, temperatures, pressures, and flow r ates. [This section has been removed and replaced with the requirements of subsection (E)(1)(b)(iii)]

(1) All Persons subject to this rule and any Person claiming any exemption under sections (D)(1)(a) and (D)(1)(b) shall comply with the following requirements: [This section has been added for enforcement purposes]

(a) Maintain and have available during an inspection, a current list of Automotive Coatings and solvents in use which provides all of the Coating data necessary to evaluate compliance, including the following information:

(i) The name and manufacturer; (ii) The Coating Category type and the mix ratio of components used; (iii) The VOC Actual and the VOC Regulatory content of each Automotive Coating as applied, or VOC content for solvent; (iii) The Targeted HAP Compounds content as applied in weight percentage; and, (v) The application method used. [The HAP requirement is added in response to 40 CFR 63 Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. Section expanded1151-30 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 to include solvents in response to ARB’s comment on D2. Subsection (F)(1)(a)(ii) was also modified to clarify the requirement of Coating Category type in response to ARB’s comments of D2]

(b) Maintain records on a daily basis including:

(i) Automotive Coating and mix ratio of components used in the Automotive Coating; (ii) Quantity of each Automotive Coating applied; (iii) Application method used to apply Automotive Coating; and, (iv) Any Person/facility utilizing an add-on Emission Control System as a means of complying with provisions of this rule shall also maintain records of key system operating and maintenance data for the purpose of demonstrating continuous compliance during periods of emission producing activities. The data shall be recorded in a manner as prescribed by the District. [Changes from CARB’s SCM for Automotive Coatings, section 5.4]

(c) Maintain records on a monthly basis for Surface Preparation and Cleaning Operations including:

(i) The name and manufacturer of the solvent used, including methylene chloride (MeCl). (i) The amount of each solvent and methylene chloride (MeCl) consumed for any use, in gallons. (ii) The weight percentage of each solvent and methylene chloride (MeCl) consumed for any use. [The MeCl requirement is added in response to 40 CFR 63 Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.]

(d) Such records shall be retained and available for inspection by the APCO for a minimum of five (5) years

.

(2) Any Person claiming any exemption under sections (D)(1)(c), (D)(1)(d), and (D)(1)(e) shall comply with the following requirements: [This section has been added forenforcement purposes and to single out recordkeeping requirements for Aerosols, halffluid ounce, and Stencil Coatings]

(b) Maintain records on a daily basis including:

(i) Exempt product type (i.e. Stencil Coating, Aerosol Coating Product, half-fluid ounce Coating); (ii) The name and manufacturer of the exempted Coating type; and,AVAQMD Rule 1151 1151-31 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (iii) The amount of the exempted Coating type.



### ( F G ) Test Methods

(1) A violation of the limits contained in this rule as determined by any one of these test
methods shall constitute a violation of this rule.

(2) The following specified test methods shall be used to determine compliance with the provisions of this rule. [Changes derived from MDAQMD 1116 for enforcement purposes]

(1) For the purpose of this rule, the f ollowing test methods shall be used to determine compliance:

(a) VOC Content of Coatings or Solvents

(i) The VOC content of Coatings or solvents shall be determined as prescribed by United States Environmental Protection Agency Reference Method 24 (without correction for Exempt Compounds) as set forth in Appendix A of Title 40 of the Code of Federal Reulations (40 CFR) Part 60, “Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Doatings”. and AS TM Test Method D4457

- 85, or ARB Method 432 for determination of emission of Exempt Compounds. Perfluorocarbon compounds shall be assumed to be absent from a product or process unless a manufacturer or facility operator identifies the specific
individual c ompounds (from the broad classes of perfluorocarbon compounds) and the amounts present in the product or process and provides a validated test method which can be used to quantify the specific compounds. [Changes made to conform with CARB’s SCM for Automotive Coatings, section 6.4]

(b) Determination of Iridescent Particles / in Metallic /Iridescent Topcoat Content

(i) The metal and silicon content of metallic/iridescent topcoat coatings shall be determined by S outh C oast A ir Q uality M anagement D istrict
Method 311 318-95, (Determination of Percent Metal in Metallic Coatings by Spectrographic Method) contained in the SCAQMD "Laboratory Method of Analysis for Enforcement Samples" manual.“Determination of Weight Percent Elemental Metal in Coatings by Xray” (July 1996). [Change made to conform with requirements of CARB’s SCM of Automotive Coatings, section 6.7]1151-32 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (c) Acid Content in Pretreatment Coatings

(i) The acid content of Pretreatment Coatings shall be determined by ASTM
Test Method D1613 -96, “Standard Test Method for Acidity in Volatile Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related Products” (May 2003 )

. [Change made to conform with requirements of CARB’s SCM of Automotive Coatings, section 6.2. Method version was changed from preliminary draft in response to USEPA’s comment that this is the only version approved by EPA.]

(d) Reflectance of Anti-Glare Safety Coatings

(i) The reflectance of Anti-Glare Safety Coatings shall be measured by
ASTM Test Method D

- 23 C523-89 (1989)

. [ Test method changed in response to USEPA’s comment on the preliminary draft to update toEPA- approved version.]

(e) Transfer Efficiency

(i) The transfer efficiency of alternative Coating application methods, as defined by subsection (C)( 3 6 )(a)(iii), shall be determined in accordance
with the S outh C oast A ir QM Quality Management D istrict method " TE - Spray Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989."

(f) Equivalent Test Methods

(i) Other test methods determined to be equivalent after review by the staffs of the District, California Air Resources Board, and the United States Environmental Protection Agency, and approved in writing by the Air Pollution Control Officer may also be used for methods of analysis.

( 2 g ) Determination of Efficiency of Emission Control Systems

( a i ) Emissions of VOC s for operations with emission Emission control
Control systems Systems shall be measured as prescribed by EPA
Reference Method 25

, or25A , or 25B for determining VOC emissions and control device efficiency, in combination with the USEPA method

, “Guidelines for Determining Capture Efficiency” (January 9, 1995) and
cited in 55 40 CFR 51, Appendix M, Methods 204-204f as applicable Federal Register (FR) 26865, June 29, 1990, for determination of capture efficiency. [Changes made to conform with CARB’s SCM for Automotive Coatings, section 6.5] (h) Determination of Methyl Acetate, Acetone, and PCBTF ContentAVAQMD Rule 1151 1151-33 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 (i) The quantity of methyl acetate , acetone, t-butyl acetate, and parachlorobenzotrifluoride shall be determined by using ASTM Method D6133-02: “Standard Test Method for Acetone, p

Chlorobenzotrifluoride, Methyl Acetate or t -Butyl Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and Raw materials by Direct Injection Into a Gas Chromatograph” (February 2003). [Added to conform with CARB’s SCM for Automotive Coatings, section 6.1]

(i) Determination of Alternative Compliance

(i) Alternative compliance shall be determined by USEPA Method 25, 25A, or 25B, Title 40 CFR Part 60, Appendix A as applicable. A source is in violation if the measured VOC emissions, as measured by any of the test methods, exceed the standards specified in Section (C)(1). [Added to conform with CARB’s SCM for Automotive Coatings, section 6.6]

(j) Exempt Compound Content

(i) Exempt compound content, other than as determined pursuant to section (G)(2)(3), shall be determined by using CARB Method 432, “Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings” (September 12, 1989); CARB Method 422, “Determination of Volatile Organic Compounds in Emissions from Stationary Sources” (September 12, 1990); or, South Coast Air Quality Management District (SCAQMD) Method 303-91, “Determination of Exempt Compounds” (August 1996). [Added to conform with CARB’s SCM for Automotive Coatings, section 6.8. Updated test version dates in response to USEPA’s comments on the preliminary draft to update to EPA-approved versions.]

(k) HVLP Equivalency

(i) Transfer Efficiency equivalent to HVLP shall be determined by procedures as prescribed in the South Coast Air Quality Management District (SCAQMD) document "Guidelines for Demonstrating Equivalency with District Approve d Transfer Efficient Spray Guns” (September 26, 2002). [Added to conform with CARB’s SCM for Automotive Coatings, section 6.10]

( 3 l ) Multiple Test Methods

( a i ) When more than one test method or set of test methods are specified for any testing, a violation of any requirement of this rule established by any1151-34 AVAQMD Rule 1151 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 one of the specified test methods or set of test methods shall constitute a
violation of the rule.



### (G) Rule 442 Applicability

(1) Any Coating operation, subject to this rule which is exempt from all or a portion of the VOC limits of this rule shall comply with the provisions of Rule 442

. [This section has been moved under section (D)(7)]

[See SIP Table at http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=921]

[SIP: Approved 04/10/00 65 FR 189 01, 40 CFR 52.220(c)(270)(I)(E)(1); Submitted as amended 03/08/96 on 07/23/96; Approved 06/13/95, 60 FR 31084, 40 CFR 52.220(c)(214)(i)(A)(1); Limited Approval/Disapproval 12/20/93, 58 FR 66286, 40 CFR 52.220(c)(193)(i)(A)(1)]AVAQMD Rule 1151 1151-35 Motor Vehicle and Mobile Equipment Coating Operations D6; 05/14/12 This Page intentionally left blank.AVAQMD Rule 1151 B-1 Staff Report, Final 06/04/12 

### APPENDIX "B"
PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing for original Governing Board Hearing of July 19,

2011.

2. Proof of Publication for Notice of Public H earing for Governing Board Hearing of May 15, 2012.B-2 AVAQMD Rule 1151 Staff Report, Final 06/04/12 This page intentionally left blank.AVAQMD Rule 1151 B-3 Staff Report, Final 06/04/12B-4 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-1 Staff Report, Final 06/04/12 

### APPENDIX "C"
PUBLIC COMMENTS AND RESPONSES

1. Email from Adrianne Borgia, USEPA, 02/22/11
2. Email attachment from Marla Hughes, AV Paints & Supply, 04/26/11
3. Email attachment from Marla Hughes, AV Paints & Supply, 04/27/11
4. Comment letter from Patrick Au, CARB, 06/20/11
5. Comment letter from American Coatings Association, 07/13/11

6. Comments on AV 1151, Draft 3, Word Document from Marla Hughes, AV Paints & Supply
02/08/12

7. Email attachment from Marla Hughes, AV Paints & Supply, 02/09/12
8. No comment letter from Patrick Au, CARB, 04/23/12
9. Email from Adrianne Borgia, USEPA, 04/26/12
10. Email from Emily Taylor, DPC – US Refinish, 05/09/12
11. Letter from Marie Hobson, Counsel, Government Affairs, American Coatings Association,
05/11/12.C-2 AVAQMD Rule 1151 Staff Report, Final 06/04/12 This page intentionally left blank.AVAQMD Rule 1151 C-3 Staff Report, Final 06/04/12 1

2

3

4

5

6

7

8

9

10

11

12

13C-4 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-5 Staff Report, Final 06/04/12 District response to Comment Letter 1

1. A specific subsection for what the rule does not apply to was added to the Applicability section or the rule as requested under subsection (A)(2)(b).
2. The definition of CARB was added under subsection (B)(14) as requested.
3. The following compounds were removed from the definition of Group II Exempt Compounds

, now under subsection (B)(28) as requested: VMA, HCFC-365, HFC-161, HSF236fa, HFC245ca, HFC-245ea, HFC-245eb, HFC-245fa, HFC-236ea, HCFC-31, HCFC123a, and
HCFC-151a.
4. The referenced definitions of VOC Actual under subsection (B)(67), correctly corresponds to
the definition of Grams of VOC per Liter of Material as listed under subsection (B)(27).
5. The referenced definitions of VOC Regulatory under subsection (B)(68), correctly corresponds
to the definition of Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds as listed under subsection (B)(26).

6. A reference under subsection (C)(1)(b) has been added to refer to the definition of Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds as listed under subsection (B)(26) as requested.

7. A statement specifically requiring at least 85 pe rcent control efficiency has been added under subsection (C)(3)(a), Emission Control System , to clarity compliance with the SCM as requested.
8. The definition of Group II Exempt Compounds , now under subsection (B)(28), has been updated to properly site 40 CFR 51.100(s)(1).
9. The words, “if applicable” were added to clarify that exempt coatings/solvents from this rule

may apply to Rule 442.
10. Subsection (F)(2)(c)(i) was updated to ASTM D1613-96 as requested as it is the version approved currently by EPA.
11. Subsection (F)(2)(d)(i) was updated to ASTM C523-89 as requested as it is the version approved currently by EPA.
12. The letters, “TE” were added in front of the title of the method listed under subsection (F)(2)(e)(i) as requested.
13. The EPA approved dates were updated in subsection (F)(2)(j) and (i) as requested.C-6 AVAQMD Rule 1151 Staff Report, Final 06/04/12 1AVAQMD Rule 1151 C-7 Staff Report, Final 06/04/12 District response to Comment Letter 2

1. An extended compliance date of 07/01/13 was added to Table 1 in subsection (C)(1)(a) of Draft 2 of the rule for the Coating Category of Single-stage Coating to allow more time for more readily available, cost-effective, premium products of this category as requested by the affected automotive coating supplier. Several of the affected facilities in the Antelope Valley AQMD jurisdiction rely on the knowledge and support of this particular supplier for quality, compliant coatings, and the District would like to maintain as smooth a transition into the new lower VOC limits as possible with minimal consequences for the affected sources. However, upon ARB’s review of the Draft 2 changes, they requested that the extended compliance date be removed, stating that other districts have already incorporated the SCM and that product availability is sufficient (see Comment Letter 4), so the AVAQMD removed the extended compliance date in the proposed Draft 3 of the rule.C-8 AVAQMD Rule 1151 Staff Report, Final 06/04/12 1AVAQMD Rule 1151 C-9 Staff Report, Final 06/04/12 District response to Comment Letter 3

1. An additional Coating Category for Vinyl Interior Coatings was added to Table 1 in subsection (C)(1)(a) of Draft 2 of the rule to allow a speci fic VOC limit for this category in response to the automotive paint supplier’s comment that there is a very limited production of compliant coatings of this nature for the proposed limit, specifically only 11 of the 60 tints necessary. Several of the affected facilities in the Antelope Valley AQMD jurisdiction rely on the knowledge and support of this particular supplier for quality, compliant coatings, and the
District would like to maintain as smooth a transition into the new lower VOC limits as possible with minimal consequences for the affected sources. However, upon ARB’s review of the Draft 2 changes, they requested that the additional coatings category be removed, stating that other districts have already incorporated the SCM and that product availability is sufficient (see Comment Letter 4), so the AVAQMD removed the additional coating category in the proposed Draft 3 of the rule.C-10 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-11 Staff Report, Final 06/04/12 1

2

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26C-16 AVAQMD Rule 1151 Staff Report, Final 06/04/12 District response to Comment Letter 4

1. Section (A)(2)(b) was amended to synchronize w ith the exemptions of subsection (D)(1) in order to clarify what the rule does not apply to.

2. Section (A)(2)(b)(iv), previously (A)(2)(b)(ii), wa s amended to read as follows: “Any Aerosol Coating Products that are in compliance with regulations and requirements adopted by the California Air Resources Board (CCR, Title 17, Subchapter 8.5, Section 94522).”

3. Section (B)(8) was renumbered to (B)(7).

4. Section (B)(7) was renumbered to (B)(8)

5. Section (B)(19), Comparison of Coating Categories , was reworded to: “This generic category has been eliminated and replaced with specific categories for the various coatings previously grouped together and are addressed below”.

6. Section (B)(19) has been amended to properly distinguish between the old category of “Adhesion Promoter” and the new category of “Primer”.

7. Section (B)(20), Color Coating , has been amended to reflect: “Any pigmented Coating, excluding Adhesion Promoters, Primers, and Multi-color Coatings, that requires a subsequent Clear Coating and which is applied over a Pr imer, Adhesion Promoter, or Color Coating. Color Coatings include metallic/iridescent Color Coatings.”

8. Section (B)(29), HVLP , has been amended to include a permanent labeling requirement. In addition, a definition of Permanently Labeled was added under Section (B)(41) to clarify this requirement.

9. The definition of Highway was removed from the rule and the definition of Roadway was added under section (B)(48).

10. The definition of Mobile Equipment was modified to include devices other than those that are self-propelled, and also to include those that can be drawn or driven on railways.

11. The definitions of Multi-colored Topcoat and Multistage Topcoat have been reversed to the correct alpha-order.

12. The definition of Reducer has been amended to reflect: “Any volatile liquid used to reduce the viscosity of the Coating. This liquid may be solvents, diluents, or both.”

13. The definition of Touch Up has been deleted from the rule as it is not used in the rule.

14. The definition of Truck Bed Liner Coating has been modified as follows: “Any Coating, excluding Clear, Color, Multi-color, and Single-stage Coatings, labeled and formulated for application to a truck bed to protect it from surface abrasion.”AVAQMD Rule 1151 C-17 Staff Report, Final 06/04/12 15. The definitions of Uniform Finish Blenders and Uniform Finish Coating were modified to clarify that they are the same type of coating. Language was added to each definition to clarify what the proper name of the coating will be before and after 07/01/12.

16. The term Highway was replaced throughout the rule to replace the term Roadway, which was
deleted from the rule.

17. The extended compliance date for Single-stage Coatings was removed in Subsection (C)(1). The additional Coating Category of Vinyl Interi or Coatings was also removed from this
section.

18. Subsection (C)(6)(a) was amended to reflect, “Except for Underbody Coatings, graphic arts operations, Truck Bed Liner Coatings, or any Co ating use of less than one (1.0) fluid ounce (29.6 milliliters), no person shall apply any Coating to Motor Vehicles or Mobile Equipment or their Associated Parts and Components unless by the use of one of the following methods:”. In addition, “brush, dip, and or roller” was added to the Application Methods. Specific language was also added to the application method of HVLP to include prohibition of sale of Automotive Refinishing guns without Permanently Labeled denotation of inlet air pressures, and an alternative compliance demonstration option for unlabeled guns.

19. Subsection (C)(7)(iii) was expanded to include Automotive Coatings and automotive coating components in the requirement of keeping these items in closed, vapor-tight containers.

20. In subsection (C)(8)(a), the word, “applies” was deleted to clarify that the prohibition is not only limited to those who apply coatings.

21. The prohibition of specification was expanded to include Surface Preparation and Cleanup Operations in section (C)(8)(b).

22. Subsection (C)(8)(c) was modified to include the words, “sale, sell, or distribute for use”.

23. Subsection (D)(4) was reconciled subsection (C)(8)(iv).

24. Subsections (E)(1)(a), (E)(2)(b), and (c) were modified to include repackagers.

25. Subsection (E)(1)(a), Manufacturer’s Compliance Statement Requirement , was expanded to
include solvent.

26. Subsection (F)(1)(a) was expanded to include solvents. In addition subsection (F)(1)(a)(ii) was modified to clarify the requirement of Coating Category type.C-18 AVAQMD Rule 1151 Staff Report, Final 06/04/12 1AVAQMD Rule 1151 C-19 Staff Report, Final 06/04/12 2

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4C-20 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-21 Staff Report, Final 06/04/12 District Response to Comment Letter 5:

1. Subsection (C)(7)(a)(i), states that, “Any Person shall not use an organic compound(s), or mixture thereof, (excluding Exempt Compounds) for Surface Preparation and Cleaning Operations with a VOC content in excess of twenty-five (25) grams per liter (0.21 pounds per gallon) of material.” The definition of Cleaning Operations , subsection (B)(16) states, “The removal of loosely held uncured adhesives, inks, Coatings, or contaminants , including, but not limited to, dirt, soil, or grease, from Motor Vehicles, Mobile Equipment, Associated Parts and Components, substrates, parts, products, tools, machinery, equipment, or general work areas.”
The District feels that the relation between these two sections satisfies the concern that the twenty-five gram per liter solvent is too low for certain cleaning and preparation operations. In addition, an aerosol solvent product exemption was added in subsection (C)(7)(a) to offer a compliant path for the need of stronger solvent use.

2. Language was added to the definition of Reducer , subsection (B)(46), to clarify that reducing solvents are not synonymous with Cleaning Operation solvents.

3. The definition of Spot Repair , subsection (B)(54), was amended to change the limit of one square foot to one panel as defined in BAAQMD’s Rule 45, Motor Vehicle and Mobile Equipment Coating Operations

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4. Section (E)(1)(A)(v) was not modified in response to this comment, as the purpose of having a Target HAP Compound percentage Compliance Statement Requirement is to insure that requirements of 40 CFR Part 63 Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Mi scellaneous Surface Coating Operations at
Area Sources are met if applicable. This portion of the Compliance Statement Requirement can be satisfied with a current MSDS for each Coating, and is not intended to require any additional labeling requirements.C-22 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-23 Staff Report, Final 06/04/12C-24 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-25 Staff Report, Final 06/04/12C-26 AVAQMD Rule 1151 Staff Report, Final 06/04/12 District Response to Comment Letter 6:

1. The Coating Category previously defined as An ti-Glare Safety Coating is now referred to as Clear Coating, Color Coating, or Single-Stag e Coating and their corresponding VOC limits.

2. Primer Sealer is a distinct Coating Category included in the SCM implementation. The
reference to Primer Sealer changing to Primer was an error in the definition of Coating Categories and has been corrected (please see, Section (B)(19)).

3. Group II Exempt Compounds , defined under Section (B)(29), are prohibited under Section (C)(4)(a).

4. The final compliance date for the proposed VOC limits is May 1, 2013, approximately one year after the expected amendment adoption, which will allow time for manufacturers, suppliers, and affected auto body shops to transition to compliant product.

5. A Multi-Stage Coating is any Coating that exhibits more than one color in the dried film after a single application, is packaged in a single container, and hides surface defects on areas ofheavy use, and which is applied over a Primer or Adhesion Promoter. Examples of a MultiStage Coating are some pearlescent type coatings.

6. The final compliance date for the proposed VOC limits is May 1, 2013, approximately one year after the expected amendment adoption.AVAQMD Rule 1151 C-27 Staff Report, Final 06/04/12 1

2C-28 AVAQMD Rule 1151 Staff Report, Final 06/04/12 District Response to Comment Letter 7:

1. In Draft 2 of the rule, an additional Coating Category for Vinyl Interior Coatings was added to Table 1 in subsection (C)(1)(a) of to allow a specific VOC limit for this category in response to the automotive paint supplier’s comment that there is a very limited production of compliant coatings of this category. However, upon ARB’s review of the Draft 2 changes, they requested that the additional coatings category be removed, stating that other districts have already incorporated the SCM and that product availability is sufficient (see Comment Letter 4), so the AVAQMD removed the additional coating category in the proposed Draft 3 of the rule.

2. An extended compliance date of 07/01/13 was added to Table 1 in subsection (C)(1)(a) of Draft 2 of the rule for the Coating Category of Single-stage Coating to allow more time for more readily available, cost-effective, premium products of this category as requested by the affected automotive coating supplier. However, upon ARB’s review of the Draft 2 changes, they requested that the extended compliance date be removed, stating that other districts have already incorporated the SCM and that product availability is sufficient (see Comment Letter 4), so the AVAQMD removed the extended compliance date in the proposed Draft 3 of the
rule. The District would like to maintain as smooth a transition into the new lower VOC limits as possible with minimal consequences for the affected sources. The final compliance date for the proposed VOC limits is May 1, 2013, approximately one year after the expected amendment adoption, which will allow time for manufacturers, suppliers, and affected auto body shops to transition to compliant product.AVAQMD Rule 1151 C-29 Staff Report, Final 06/04/12C-30 AVAQMD Rule 1151 Staff Report, Final 06/04/12 1

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4AVAQMD Rule 1151 C-31 Staff Report, Final 06/04/12 District Response to Comment Letter 9:

1. The second sentence use of “automotive” in definition (B)(9) was not capitalized as “automotive refinishing” is not a definition. Only definitions are capitalized in rule format.

2. The spelling of “Specialty” was corrected in the table of definition, (B)(19).

3. The deletion of some of the toxins in definition (B)(28) in the previous drafts will remain in the
final amendment. The District wishes to be consistent with the SCM.

4. This comment is not accurate. Perhaps the title of Rule 442, Usage of Solvents, alludes that it is only applicable to solvents but the actual applicability is broader. Rule 442, is applicable to any person using VOC containing materials which is not subject to the VOC limits of any other rule found in District Regulation IV – Prohib itions or in any rule found in the District Regulation XI – Source Specific Standards. Th is includes VOC containing materials include, but are not limited to; coatings, resins, adhesives, inks, solvents, thinners, diluents, mold seal and release compounds, lubricants, cutting oils and quenching oils. This rule also applies to any person using a Non-VOC organic solvent and which is not subject to the limits of any other rule found in District Regulation IV – Prohibitions or in any rule found in District Regulation XI – Source Specific Standards.C-32 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-33 Staff Report, Final 06/04/12C-34 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-35 Staff Report, Final 06/04/12 District Response to Comment Letter 10:

1. In response to the above comment letter, the compliance date for the proposed VOC limit for solvent has been modified in the current staff report version to reflect May 1, 2013. This was a typographical error, as the date in the subseque nt staff reports should have been corrected to reflect May 1, 2013. This change has been made in this current staff report.C-36 AVAQMD Rule 1151 Staff Report, Final 06/04/12AVAQMD Rule 1151 C-37 Staff Report, Final 06/04/12C-38 AVAQMD Rule 1151 Staff Report, Final 06/04/12 District Response to Comment Letter 11:

1. In response to ACA’s comment on the Compliance Statement including additional requirements for solvents than the SCM requires, a separate section was made for solvents under (E)(1)(b), which only includes the requirement of VOC Actual as the SCM requires. The second comment on the requirements of HAPs Content requirement for Coatings will remain, as this is the District’s mechanism to ensure compliance with the NESHAP 6H.

2. In response to ACA’s request for solvent to be clarified as a ‘cleaning’ solvent, language was added to section (C)(7)(b) to read, “Effective May 1, 2013, no Person shall possess at any Automotive Refinishing Facility, any solvent used for Surface Preparation and Cleaning Operations with a VOC content that does not comply with the requirements in subsection (C)(7)(a)(i).”

3. In response to the ACA’s comment to incl ude a ‘Sell-Through’ provision, the District purposefully established a compliance date of twelve months after the proposed adoption date to allow a window for the sell and use of products manufactured before the date.

4. For clarification on the VOC limit for Group I Specialty Coatings (Table 2), the proposed interim VOC limit, effective until May, 1, 2013 is 840 g/L. After May 1, 2013, the proposed limit for Adhesion Promoter (which includes Unif orm Finishing Coating) is 540 g/L (Table 2).

5. The District notes the ACA’s support of the exemption of TBAC as implemented in this proposed revision.

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### APPENDIX "D" CALIFORNIA ENVIRONMENTAL QUALITY ACT
DOCUMENTATION

1. Notice of Exemption, Los Angeles CountyD-2 AVAQMD Rule 1151 Staff Report, Final 06/04/12 This page intentionally left blank.AVAQMD Rule 1151 D-3 Staff Report, Final 06/04/12D-4 AVAQMD Rule 1151 Staff Report, Final 06/04/12 This page intentionally left blank.AVAQMD Rule 1151 E-1 Staff Report, Final 06/04/12 

### APPENDIX "E"
BIBLIOGRAPHY

The following documents were consulted in the preparation of this staff report.

Statutes and Regulations

EPA 450/2-76-028 (1976/11) – Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume I: Control Methods for Surface Coating Operations

EPA 450/2-77-008 (1977/05) – Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
Trucks

EPA 450/2-78-015 (1978/06) – Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and Products

EPA 450/3-88-009 (1988/10) – Reduction of Volatile Organic Compound Emissions from Automobile Refinishing

EPA 453/R-08-003 (2008/09) – Control Techniques Guid elines for Miscellaneous Metal and Plastic Parts Coatings

EPA 453/R-08-006 (2008/09) – Control Techniques Guid elines for Automobile and Light-Duty Truck Assembly Coatings

EPA 453/R-94-031 (1994/04) – Alternative Control T echniques Document: Automobile Refinishing

40 CFR 63 Subpart HHHHHH – National Emission Sta ndards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Opera tions at Area Sources; Final Rule (January 9, 2008)

40 CFR 60 Subpart MM – Standards of Performance for Automobile and Light Duty Truck Surface Coating Operations

Title 17 CCR, Section 93112 – Hexavalent Chromium and Cadmium Airborne Toxic Control Measure – Motor Vehicle and Mobile Equipment Coatings

Local Air Districts

Rule 45 – Motor Vehicle and Mobile Equipment Coating Operations (Bay Area Air Quality Management District, 12/03/08)E-2 AVAQMD Rule 1151 Staff Report, Final 06/04/12 Rule 1116 – Automotive Refinishing Operations (Mojave Desert Air Quality Management District, amended, 08/23/10)

Rule 1151 – Motor Vehicle and Mobile Equipment Non-assembly Line Coating Operations (South Coast Air Quality Management District, amended 12/02/05)

Rule 1171 – Solvent Cleaning Operations (South Coast Air Quality Management District, amended, 02/01/09)

Rule 4612 – Motor Vehicle and Mobile Equipment Coating Operations – Phase II (San Joaquin Valley Unified Air Pollution Control District, amended 09/20/07)

Staff Report for Proposed Amended Rule 1116: Automotive Refinishing Operations (Mojave Desert Air Quality Management District, June 2008)

Staff Report for Proposed Amended Rule 1151: Motor Vehicle and Mobile Equipment Non-assembly Line Coating Operations (South Coast Air Quality Management District, December 2005)

Staff Report for Proposed Amendments to Rules 4602 ( Motor Vehicle and Mobile Equipment Coating Operations ) and 4612 ( Motor Vehicle and Mobile Equipment Coating Operations –Phase II ) (San Joaquin Valley Unified Air Pollution Control District, September 21, 2006)

SIP Citations

Rule 1116 (Mojave Desert Air Quality Management District) 65 FR 18901, Approval of 7/31/99 version

Rule 1151 (Antelope Valley Air Quality Management District) 65 FR 18901, Approval of 07/20/99 version

Rule 1151 (South Coast Air Quality Management District, for Blythe/Palo Verde Valley) 58 FR 66286, Limited approval/limited disapproval of 09/06/91 version

Rule 4612 (San Joaquin Unified Air Pollution Control District) 75 FR 279, Approval of 09/20/07 version

Technical Support Document for EPA’s Proposed Ru lemaking for the California State Implementation Plan: San Joaquin Valley Air Pollution Control District, Rule 4612, Motor Vehicle and Mobile Equipment Coating Operations – Phase II (United St ates Environmental Protection Agency, Region IX Air Division, May 2009)

Miscellaneous

8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT SIP Analysis) (Mojave Desert Air Quality Management District, August 2006)AVAQMD Rule 1151 E-3 Staff Report, Final 06/04/12 List and Implementation Schedule for District Measur es to Reduce PM Pursuant to Health & Safety Code §39614(d) (Mojave Desert Air Quality Management District, June 27, 2005)

Staff Report for the Proposed Suggested Control Measure for Automotive Coatings (California Air Resources Board, Stationary Source Division Measures Assessment Branch, October, 2005)

Suggested Control Measure for Automotive Coatings as Approved by the Board on October 20, 2005 – Attachment A (California Air Resources Board, Stationary Source Division Measures Assessment Branch, October 20, 2005)E-4 AVAQMD Rule 1151 Staff Report, Final 06/04/12 This page intentionally left blank.