PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

PROPOSED NEW RULE 249,

SURFACE COATING OF PLASTIC PARTS AND PRODUCTS

August 8, 2013
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SUMMARY

The District is required to adopt volatile organic compounds (VOCs) standards at least as stringent 

as contained in the U.S. EPA “Control Techniques Guidelines for Miscellaneous Metal and Plastic 

Parts Coatings” (CTG), September 2008. Rule 245, Surface Coating of Metal Parts and Products,

was amended August 20, 2009 to meet the requirements for metal parts. Adoption of this proposed 

new Rule 249, Surface Coating of Plastic Parts and Products, would meet the requirements for 

plastic parts.

A draft version of Rule 249 was forwarded to the U.S. EPA on May 29, 2013, for review and 

comment. Comments were received on June 26, 2013. The District revised Rule 249 and re-sent 

the Rule to EPA for final comments. EPA indicated that the changes to the Rule were fine and 

there were no further comments.

BACKGROUND

Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans (SIPs) for 

nonattainment areas must include “reasonably available control measures” (RACM) including 

“reasonably available control technology” (RACT) for sources of emissions. Section 182(b)(2)(A) 

provides that for certain nonattainment areas, states must revise their SIPs to include RACT for 

each category of volatile organic compound (VOC) sources covered by a control techniques 

guidelines (CTG) document issued between November 15, 1990, and the date of attainment.

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest

emission limitation that a particular source is capable of meeting by the application of control

technology that is reasonably available considering technological and economic feasibility.

DISCUSSION OF THE PROPOSED RULE

Placer County currently has only one minor source, Freedom Refinishing, under permit which 

would be required to meet the requirements of this rule. The owner indicates that he occasionally 

coats plastic parts and the total plastic parts coated amounts to approximately 2% of his business.

He uses the same paint to coat plastic as he uses for metal parts. The company is currently in 

compliance with the proposed rule.

The following is a summary of the rule sections.

Applicability:

The rule applies throughout all of Placer County.

Exemptions:

Section 104 contains a low usage exemption for non- compliant coatings used in quantities of less 

than 55 gallons, if substitute compliant coatings are not available, and (2) the requirements of 

Sections 401 and 501 are met.
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Section 105 contains the exemptions for operations and coating which are covered by other 

specific rules.

Section 106 contains partial exemptions for coating operations used for repair and touchup. 

Coating operations used for repair and touchup are exempt from all sections of the rule except the 

application method requirements of Section 302, surface preparation and cleanup of Section 303, 

the work practices requirements of Section 304, and the recordkeeping requirements of Section 

501 shall apply.

Coating operations used for stencil, safety indicating, solid film lubricating, electric insulating, 

thermal conduction, and magnetic data storage, are exempt from all sections of the rule except the 

application method requirements of Section 302, surface preparation and cleanup of Section 303, 

the work practices requirements of Section 304, and the recordkeeping requirements of Section 

501 shall apply.

Definitions:

The definitions were based on definitions used in other District Rules or in EPA’s CTG.

Standards:

The VOC limits are listed in Table 1 of Section 301. The limits are expressed in both grams per 

liter and pounds per gallon (lb/gal). 

The coating categories covered are; general one component, general multi-component, and 

specialty coating categories of: electric dissipating and shockfree coating, extreme performance (2 

pack), metallic, military specification (1 pack), military specification (2 pack), mold seal, multicolored, optical and vacuum metalizing.

Administrative:

The administrative requirements contain prohibition of specification, product information 

requirements for sellers, formula for determining the VOC Content of the coatings, formula for 

determining the VOC Content per Liter of Coating Removers (Strippers), surface preparation 

materials, and cleanup materials.

Monitoring and Records:

Standard recordkeeping is required, including a monthly record of the volume of each product 

used.

Records must be retained for at least 3 years, unless the source is a Title V source subject to Rule 

507, Federal Operating Permit Program.
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FINDINGS

FINDING DEFINITION REFERENCE

Authority The District is permitted or required to 

adopt, amend, or repeal the rule by a 

provision of law or a state or federal 

regulation.

California Health and Safety Code, 

Section 40702 and Section 41010; 

1990 Federal Clean Air Act, Section 

110(a) (2) (H) and Section 182(d).

Necessity The District has demonstrated that a need 

exists for the rule, or for its amendment or 

repeal.

The adoption of proposed new Rule 

249 is necessary to satisfy the 

requirement that U.S. Environmental 

Protection Agency “Control 

Techniques Guidelines for 

Miscellaneous Metal and Plastic 

Parts Coatings” (CTG) be 

implemented.

Clarity The rule is written or displayed so that its 

meaning can be easily understood by the 

persons directly affected by it.

There is no indication at this time 

that the rule is not written in such a 

manner that the person affected by 

the rule can easily understand it.

Consistency The rule is in harmony with, and not in 

conflict with or contradictory to, existing 

statutes, court decisions, or state or federal 

regulations.

The District has found that the rule is 

consistent with existing state and 

federal guidelines.

Non-duplication The rule does not impose the same 

requirements as an existing state or federal 

regulation, unless the District finds that the 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District.

There are no other duplicate 

requirements in federal law. The 

limits came from the CTG, which is a 

guideline to agencies.

Reference Any statute, court decision, or other 

provision of law that the District implements, 

interprets, or makes specific by adopting, 

amending, or repealing the rule. An example 

of this would be the 1988 EPA State 

Implementation Plan call to revise District 

rules.

This rule is being proposed because 

of the requirements of the Federal 

Clean Air Act Amendments of 1990.

SUMMARY

District staff recommends the District Board approve the Findings in this document and adopt the 

proposed new Rule 249, Surface Coating of Plastic Parts and Products, with standards for plastic 

parts and products as contained in the U.S. EPA “Control Techniques Guidelines for 

Miscellaneous Metal and Plastic Parts Coatings” (CTG), September, 2008.