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 218, Architectural Coatings

Prepared by: David Grounds and Idalia Perez

Reviewed by: Andrew Steckel

September 29, 2011
RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: Rule 218 – Architectural Coatings

Adopted – February 9, 1995

Submitted – May 24, 1995

EPA Approved – July 18, 1996 (61 FR 37390) 

Previous Rule Submittals There are no outstanding submittals of Rule 218, although 

other versions were adopted locally in 1997 and 2001.

Subject of this TSD: Rule 218 – Architectural Coatings

Amended – October 14, 2010

Submitted – April 5, 2011

RULE SUMMARY – PCAPCD Rule 218, Architectural Coatings, limits the volatile 

organic compound (VOC) content of architectural coatings that may be used, sold, or 

manufactured in the District. The rule has a compliance deadline of July 1, 2011.

Changes from the approved SIP rule include:

In section 200, twenty (20) new definitions of coating categories were added that 

will be effective July 1, 2011.

In section 300, new coating categories and VOC limits were added.

In section 301, seventeen (17) coating categories were eliminated and the coatings 

become subject to other limits after July 1, 2011.

In section 302, exemptions from the most restrictive VOC limits were made 

consistent with the coating categories of the SCM.

In section 303, the “Averaging Program” provision was deleted.

In section 306, non-flat high gloss category was added.

In section 401.3, VOC content labeling requirements were modified.

In section 501.1, added “Sales Data”, requiring that coating manufacturers

provide, within 180 days the request of the CARB or District, information of 

product volume sales and product VOC composition.

In section 502, added recordkeeping and reporting be kept for 3 years.

In section 503.4, added additional test methods.

PCAPCD held a rulemaking workshop in August 2010 and a Public Hearing in October 

2010. Both meetings included Rule 218 amendments on the agenda. Comments were 

received from American Coatings Association (ACA) and Roof Coatings Manufacturers 

Association (RCMA). ACA expressed concern that the industry would not have enough 

time to prepare for implementation and requested the District adopt a January 1, 2012 

implementation date instead. RCMA stated the 2007 SCM limits are simply too 

restrictive and requested that the limits for the categories effecting roof coatings be 

adjusted.
Effects on Emissions: 

According to documentation sent along with the rule submittal, the District estimates a 

reduction of 0.18 tons/day of Reactive Organic Gas (ROG, similar to VOC) based on 

2008 emission inventory, due to the implementation of this rule. 

EPA EVALUATION CRITERIA – The following criteria were used to evaluate the 

submitted Rule 218:

Rule Stringency – Section 172(c)(1) of the Clean Air Act (CAA) requires non-attainment 

areas to implement all reasonably available control measures (RACM), including such 

reductions in emissions from existing sources in the area as may be obtained through the 

adoption, at a minimum, of reasonably available control technology (RACT), as 

expeditiously as practicable. In addition, ozone non-attainment areas classified as 

moderate or above must require RACT for all major sources of VOCs and sources 

covered by a CTG issued after November 15, 1990 and prior to the areas date of 

attainment (CAA § 182(e); 40 CFR § 51.912(a)). The PCAPCD regulates an ozone nonattainment area that is classified as severe for both the 1-hr ozone and 8-hr ozone 

standards (40 C.F.R. § 81.305 (2010)). EPA’s National Volatile Organic Compound 

Emission Standard for Architectural Coatings (40 CFR Part 59 Subpart D), CARB’s 

Suggested Control Measures for Architectural Coatings (October 26, 2007), and 

analogous rules in nearby areas (e.g., Imperial County Air Pollution Control District Rule 

424, Ventura County Air Pollution Control District Rule 74.2, and Kern County Air 

Pollution Control District Rule 410.1A) were used to help evaluate the rule stringency.

Enforceability – the Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook (Guidance 

Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, 

August 21, 2001) were used to help evaluate compliance with the CAA 110(a)(2)(A) 

requirements for enforceability.

SIP Revisions - We have evaluated this SIP revision to determine whether it would 

interfere with any applicable requirement concerning attainment and reasonable further 

progress (RFP) or any other applicable requirement of the Act (CAA 110(l)) or modify, 

in a nonattainment area, any SIP-approved control requirement in effect before 

November 15, 1990 (CAA 193).
EPA EVALUATION

Rule Stringency – The District amended Rule 218 based on a Suggested Control Measure 

for Architectural Coatings (SCM) issued on October 26, 2007 by the California Air 

Resources Board. The SCM provides VOC limits for 19 coating categories that are more 

stringent than those in current Rule 218. Submitted Rule 218 is not subject to RACT 

requirements because it is applicable to sources that are too small to exceed the major 

source threshold of 25 tpy, and no CTG is available for this category. The stringency of 

requirements in submitted Rule 218 is also generally consistent with relevant national 

guidance and analogous rules in other areas. Based on the consistency of this rule with 

the SCM, we believe Rule 218 imposes reasonably available control measures, and we 

will make a more general RACM determination in separate action on the Sacramento 

area plan.

Enforceability – The current SIP submittal is clear and generally contains sufficient 

testing and recordkeeping requirements to satisfy enforcement requirements. 

SIP Revisions –The submitted PCAPCD Rule 218 is more stringent than the approved 

SIP, largely because of the new VOC content limits for architectural coatings, increased 

recordkeeping details, and added test methods. We propose to determine that our 

approval of the submittal would comply with CAA sections 110(l) and 193, because the 

proposed SIP revision would not interfere with the on-going process for ensuring that 

requirements for RFP and attainment of the NAAQS are met, and the submitted SIP 

revision is at least as stringent as the rule previously approved into the SIP.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 218 sufficient 

for EPA to propose less than full approval.

EPA ACTION – The rule largely fulfills the relevant CAA 110 and Part D requirements. 

EPA staff recommends approval of Rule 218 pursuant to CAA 110(k)(3) and 301(a).

REFERENCES –

PCAPCD Rule 218, Architectural Coatings, Adopted February 9, 1995.

PCAPCD Rule 218, Architectural Coatings, Staff Report, October 14, 2010.

PCAPCD Rule 218, Architectural Coatings, Adopted October 14, 2010.