UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA ’ s Direct Final Rulemaking

For the California State Implementation Plan

Placer County Air Pollution Control District

, Rule 234

, Automotive Refinishing Operations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

September 201 12

Agency: Placer County Air Pollution Control District ( P CAPC D)

Superseded Submittals: A dopt ed

– November 3, 1994

Submitted

– January 24, 1995

Subject of this TSD: Rule 234

– Automotive Refinishing Operations

Amended

– Octo ber 14, 2010 (effective July 1, 2011)

Submitted

– April 5, 2011

RULE SUMMARY

- P C APCD Rule 234

, Automotive Refinishing Operations

, is a rule designed to limit volatile organic compound (VOC) emissions from facilities engaged in coating operations of motor vehicles and mobile equipment . It also limits VOC emissions from organic solvent cleaning and storage and disposal of

solvents and waste solvent materials associated with such coating. The rule describes related recordkeeping, reporting, and monitoring requirements and test methods for determining various VOC content and emissions. In general, the

rule was changed to reflect the CARB Suggested Control Measure (SCM) for Automotive Coatings as approved by the Board on October 20, 2005.

EPA EVALUATION

- The following criteria were used to evaluate the submitted

rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988), the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule

Deficienci

es, EPA Region 9, August 21, 2001), and State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air

Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

– Primarily

, the California’s SCM en titled “Suggested Control Measure for Automotive Coatings” as approved b y the board on October 20,

2005 , was used to evaluate RACT requirements of CAA §182(b)(2) . Other district rules for this category were used for comparison including: San Joaquin Valley Unified Air Pollution Control District ( S J V UAPC D ) Rule 4612

, amended Septem ber

, 200 7 , Bay Area Air Quality Management District’s ( BAAQMD) Rule 8

- 45 amended December, 2008 and Yolo

- Solano Air Quality Management District’s ( YSAQMD) Rule 2.26, revised December 10,

2008.

Rule 234 was also partially evaluated against E PA’s “Control Techniques

Guidelines (CTG) for Industrial Cleaning Solvents” (EPA

- 453/R

- 06

- 001 September 2006), “CTG for Miscellaneous Metal and Plastic Parts” (EPA

453/R

- 08

- 003, September 2008) and “CTG for Automobile and Light

- Duty Assembly Coatings” (EP A

- 453/R

- 08

- 006, September 2008).3

3. SIP Rela xation

– Since no previous version of these requirements is already in the SIP, approval of this version only improves the SIP and does not relax

the SIP in violation of CAA section § 110(l) or § 193.

Enforceability

- The monitoring, recordkeeping, reporti ng and other requirements generally ensure that Rule 234 can be enforced.

Stringency

– We believe the CARB Automotive Coating SC M approved by the Board on October 20, 2005, basic ally define s RACT for this activity in California

since the SCM generally has more stringent VOC limits than the CTG and is also adopted by other local districts including SJ V UAPCD, BAAQMD and YSAQMD

. Rule 234 implements RACT because it is generally as stringent as the SC M and analogous rules in other California Districts . Rule 234 is also more stringent than

the SC M because it restricts the use of two toxins

, c admium and hexavalent

chromium

, and requires records of maintenance work that interferes with emission control equ ipment.

SIP Relaxation

– The new submittal generally complies with CAA § 110(l) and § 193 regarding SIP relaxations.

EPA ACTION

- EPA staff recommends a full approval of Rule 234 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

–

1. SMAQMD Rule 459 further defines the exempted assembly lines as “...an assembly line at an original equipment manufacturing plant.” For clarification, we recommend this language be added to the description of

Section 104.3 Exemption, Assembly Line: “ The provisions of this rule shall not apply to any coating applied to motor vehicles or mobile equipment, or their associated parts, and components during manufacture on an assembly line at an ori ginal equipment manufacturing plant.”

2. For c larity, please consider revising the definition of “Control Efficiency” in

Section 213 to “The ratio , in percentage, of the pollution prevented by a

control device to the pollution introduced to the control devic e.”

3. To avoid confusion , we recommend this section be revised accordingly : “ VOC s olvents that meet the requirements of section

305.4 shall only be used for the cleanup of spray equipment including paint lines in enclosed system s

. Such enclosed system s must enclose spray guns, cups, nozzles, bowls and other parts during washing, rinsing and draining procedures. Equipment used shall minimize evaporation of organic materials to the atmosphere. Spray equipment may be cleaned without the use of an enclosed system if cleaning solutions that do not contain VOCs are used. ”4

4. To avoid ambiguity, please consider adding the following statement from the SCM to the end of Section 402 Prohibition of Specification: “This prohibition shall not apply to coatings that me et the criteria specified in

section 403.2”

5. For completeness and compliance with the Little Bluebook , please add

“ October 2006” after “ASTM Method D1613

- 06 “Standard Test Method for Acidity in Volatile Solvents and Chemical Intermediates Use in Paint,

Var nish, Lacquer, and Related Products.”

6. For clarity and consistency with the SCM , please revise Section 501.2 to : “Current manufacturing specification sheets, technical data sheets, material data sheets or current air quality data sheets which list the VOC actual content and VOC regulatory content of each automotive coating, automotive coating component, ready

- to

- sp ray mixture (based on the

manufacturer’s and re

- packager’s stated mix ratio) or which list the VOC

content of each solvent.”

7. We recommend changing the recording requirement in Section 501.3 from monthly to daily usage records. While the SC M does not require usage records, no less frequent than daily records are generally needed to support the CAA provisions for daily violations.

8. Consider adding a sub

- section in Section 507 for a test for Metallic Content

us ing SCAQMD Method 318

- 95, “Determination of Weight Percent Elemental Metal in Coatings by X

- ray” (July 1996)

.

ADDITIONAL REFERENCES

-

1. P CAPCD Rule 234

, Surface Automotive Refinishing Operations , as submitted on April 5, 2011

.

2. “Automotive Coatings Suggested Control Measure

, ” as approved by the Board on October 20,2005 http://www.arb.ca.gov/coatings/autorefin/scm/sreport/appenda.pdf

3. “Control Techniques Guidelines for Automobile and Light

- Duty Truck Assembly,” EPA

- 453/R

- 08

- 006, September 2008. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 006_auto _ldtruck_assembly_coating.pdf

4. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings,” EPA

- 453/R

- 07

- 003, September 2008. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf

5. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.5

6. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.