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 2011
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Agency: Placer County Air Pollution Control District (PCAPCD)

Superseded Submittals: Adopted – November 3, 1994

Submitted – January 24, 1995

Subject of this TSD: Rule 234 – Automotive Refinishing Operations 

Amended – October 14, 2010 (effective July 1, 2011)

Submitted – April 5, 2011

RULE SUMMARY - PCAPCD 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 

Deficiencies, 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 entitled “Suggested Control 

Measure for Automotive Coatings” as approved by 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 (SJVUAPCD) Rule 4612, 

amended September, 2007, 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 EPA’s “Control Techniques 

Guidelines (CTG) for Industrial Cleaning Solvents” (EPA-453/R-06-001 

September 2006), “CTG for Miscellaneous Metal and Plastic Parts” (EPA453/R-08-003, September 2008) and “CTG for Automobile and Light-Duty 

Assembly Coatings” (EPA-453/R-08-006, September 2008).
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3. SIP Relaxation – 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, reporting and other requirements 

generally ensure that Rule 234 can be enforced. 

Stringency – We believe the CARB Automotive Coating SCM approved by the 

Board on October 20, 2005, basically defines 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 SJVUAPCD, BAAQMD and YSAQMD. 

Rule 234 implements RACT because it is generally as stringent as the SCM and 

analogous rules in other California Districts. Rule 234 is also more stringent than 

the SCM because it restricts the use of two toxins, cadmium and hexavalent 

chromium, and requires records of maintenance work that interferes with emission 

control equipment. 

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 original equipment manufacturing plant.”

2. For clarity, 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 device.”

3. To avoid confusion, we recommend this section be revised 

accordingly: “VOC solvents that meet the requirements of section 

305.4 shall only be used for the cleanup of spray equipment 

including paint lines in enclosed systems. Such enclosed systems

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.” 
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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 meet 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, 

Varnish, 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-spray 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 SCM 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 

using SCAQMD Method 318-95, “Determination of Weight Percent 

Elemental Metal in Coatings by X-ray” (July 1996).

ADDITIONAL REFERENCES -

1. PCAPCD 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.
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6. “Guidance Document for Correcting Common VOC & Other Rule 

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