SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis November 21, 2010 

B-1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

APPENDIX B 

Rule Consistency Analysis 

November 21, 2010 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis November 21, 2010 

B-2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis November 21, 2010 

B-3 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting, 

amending, or repealing a rule or regulation, the District is required to perform a written 

analysis that identifies and compares the air pollution control elements of the rule or 

regulation with corresponding elements of existing or proposed District and United 

States Environmental Protection Agency (EPA) rules, regulations, and guidelines that 

apply to the same source category. The elements analyzed are emission standards, 

monitoring and testing, and recordkeeping and reporting requirements. 

II. RULE CONSISTENCY ANALYSIS 

A. District Rules 

Facilities subject to District Rule 4612 could be subject to other District rules including: 

 Rule 2201 New and Modified Stationary Source Review 

 Rule 4001 New Source Performance Standards 

 Rule 4002 National Emissions Standards for Hazardous Air Pollutants 

 Rule 4101 Visible Emissions 

 Rule 4102 Nuisance 

 Rule 4201 Particulate Matter Concentration 

 Rule 4661 Organic Solvents 

 Rule 4663 Organic Solvent Cleaning, Storage, and Disposal 

The above-listed rules are not in conflict with, nor are they inconsistent with the 

requirements of Proposed Rule 4612. 

B. Federal EPA Rules and Regulations 

Federal Control Techniques Guideline (CTG) 

1. EPA-450/2-76-028 1976/11 Control of Volatile Organic Emissions from Existing

Stationary Sources - Volume I: Control Methods for Surface Coating Operations 

The CTG applies to surface coating operations located in marginal, moderate, serious 

or severe ozone nonattainment areas that has the potential to emit greater than or equal 

to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme 

ozone nonattainment areas. This CTG will not be compared to District Rule 4612 since 

the source category (Motor Vehicle and Mobile Equipment Coating) is addressed in 

another CTG: EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from 

Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks (See discussion below). 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis November 21, 2010 

B-4 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

2. EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing

Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks 

The CTG applies to motor vehicle surface coating operations located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to emit 

greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of 

VOC for extreme ozone nonattainment areas. The table below identifies the CTG 

requirements and how Rule 4612 compares to the automobile and light-duty truck 

coating requirements. 

Table B1 - Rule and CTG Comparison 

Coating Type CTG (lb/gal) Rule 4612 (lb/gal) 

Prime 2.8 2.1 

Topcoat 4.2 2.1 

Final Repair Topcoat 5.5 2.1 

3. EPA-453/R-08-006 2008/09 Control Techniques Guidelines for Automobile and LightDuty Truck Assembly Coatings 

The CTG applies to vehicle assembly coating operations located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit greater than 

or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 

extreme ozone nonattainment areas. There are no vehicle assembly plants in the 

District; therefore, this CTG will not be examined.

Alternative Control Technology (ACT) 

EPA-453/R-94-017 1994/02 Alternative Control Techniques Document - Surface 

Coating of Automotive/Transportation and Business Machine Plastic Parts 

The ACT applies to the coating of plastic parts for the automotive industry, business 

machines, and other miscellaneous plastic parts. The ACT identifies an automotive 

coating work practice standards, VOC content limits, application methods, and add-on 

control efficiencies based on California District rules as of 1994. Since SJVAPCD Rule 

4612 is at least as stringent overall compared to other Districts (see analysis below in 

Section III), a detailed evaluation of the ACT is not necessary. 

Federal New Source Performance Standards (NSPS) 

40 CFR 60 Subpart MM (Standards of Performance for Automobile and Light Duty 

Truck Surface Coating Operations) applies to assembly plant coatings.

There are no vehicle assembly plants in the District; therefore, this NSPS will not be 

examined. 

National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Performance Standards (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis November 21, 2010 

B-5 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

40 CFR 63 Subpart IIII (National Emission Standards for HAPs: Surface Coating of 

Automobiles and Light-Duty Trucks) 

The requirements in this subpart are not directly comparable to the District Rule 4612 

limits. The NESHAP HAP emission limits which are expressed in terms of % HAP, HAP 

emission concentration, and mass (kg) of HAP per mass (kg) of solids are not directly 

comparable to the coatings VOC limit which is expressed in terms of grams (or lb) of 

VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In 

addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, 

there is no direct correlation between the NESHAP limits versus District Rule 4612 VOC 

limits.

EPA Policy on Recordkeeping 

The recordkeeping requirement in Rule 4612 is consistent with EPA’s policy to keep 

and maintain records for at least five years. 

III. CONCLUSION 

Based on the above analysis, District staff found that the proposed amendments to Rule 

4612 would not conflict with federal rules, regulations, or policies covering similar 

stationary sources. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis November 21, 2010 

B-6 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

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