UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region IX AIR DIVISION

Technical Support Document 

For

EPA’s Direct Final Rulemaking 

For the 

California State Implementation Plan

Mojave Desert Air Quality Management District 

Rule 1116, Automotive Refinishing Operations

Prepared by: Sally Grady

Reviewed by Andrew Steckel

April 2012
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Rule Identification

Agency: Mojave Desert Air Quality Management District (MDAQMD)

SIP APPROVED RULE: Rule 1116 – Automotive Refinishing Operations

Adopted – April 26, 1999

Submitted – July 23, 1999 

EPA Approved - April 10, 2000 (65 FR 18901)

Subject of this TSD: Rule 1116 – Automotive Refinishing Operations

Amended - August 23, 2010

Submitted – April 5, 2011

 

RULE SUMMARY – The MDAQMD previously submitted Rule 1116 – Automotive 

Refinishing Operations on July 23, 1999 which EPA approved on April 10, 2000. The

version of Rule 1116 submitted on April 5, 2011 revised all sections of the earlier Rule 

1116. Section (A), General, was expanded for clarity. In Section (B), eleven definitions

were deleted and 36 added. Section (C)(6)(iii) allows the use of other coating 

applications, adds other requirements when using emission control systems and

restricts use of automotive coating which contain Group II exempt compounds,

cadmium or hexavalent chromium. This rule sets out the limited conditions under which

automotive coatings that are not in compliance with subsection (C)(1) may be used. 

MDAQMD has expanded (D), Exemptions, to include any coating that is:

1. Applied to motor vehicles during manufacture on an assembly line, 

2. Applied to prototype motor vehicles,

3. Manufactured for use outside the District or for shipment, reformulation or

repackaging,

4. Sold, supplied or offered for sale in 0.5 fluid ounces or smaller containers, or

5. Applied for educational purposed at coating training centers.

MDAQMD has revised section (F), Monitoring and Records, to make it consistent with 

advances in automotive coating operations. Revisions include: 

1. Added targeted HAP compounds to the information required in (F)(1)(a),

2. Added the application method used to (F)(1)(a) and (F)(1)(b),

3. Defined information to be included in (F)(1)(c), and

4. Lengthened the time records shall be retained from two to five years.

MDAQMD has added three test methods to Section (G):

1. (G)(2)(c)(I) Determination of HVLP Transfer Efficiency Equivalence,

2. (G)(2)(g)(i) Determination of Methyl Acetate, Acetone, and PCBTF Content,
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3. (G)(2)(h)(i) Exempt Compound Content.

EPA EVALUATION CRITERIA – The following criteria and guidance documents were 

used to evaluate the submitted Rule 1116.

Enforceability –The Little Bluebook (“Guidance Document for Correcting Common 

VOC & Other Rule Deficiencies,” EPA Region 9, August 21, 2001), and The Bluebook 

(“Issues Relating to VOC Regulation Cutpoints, Deficiencies and Deviations”, EPA 

1988), were used to help evaluate compliance with the CAA §110(a)(2)(A) requirement 

for enforceability.

Stringency – CARB “Suggested Control Measure for Automotive Coatings”, (SCM, 

October 20, 2005), EPA’s “Control Techniques Guideline for Automobile and Light-Duty 

Truck Assembly Coatings”, (CTG, September 2008) and other state and local rules for 

this category were used to help evaluate the RACT requirements of CAA §172(c)(1) and 

§182(b)(2).

SIP Relaxation –We have evaluated this proposed 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

The monitoring, recordkeeping, reporting and other requirements ensure that Rule 1116 

can be adequately enforced. 

The VOC limits and other requirements of this rule are as stringent as those described 

in EPA’s CTG and CARB’s SCM, and generally consistent with analogous rules in other 

California Ozone nonattainment areas. As a result, we conclude that this revision is 

consistent with the RACT requirements of CAA §182(b)(2) and §182(f).

The April 2011 submitted version of Rule 1116 is more stringent than the provisions 

currently in the SIP because rule applicability is expanded and VOC limits tightened 

consistent with the SCM; definitions are updated to make the rule more comprehensive 

and clear; work practice requirements have been added; and the monitoring, 

recordkeeping and test method sections have been strengthened. As a result, we 

conclude that this revision will not 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).
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RECOMMENDED FOR THE NEXT RULE REVISION – The following revisions are 

recommended for the next time the rule is amended; 

1. Section (C)(7)(a) refers to three exceptions to the requirements of (C)(1). This 

should be included in section (D) exemptions.

2. (F)(1)(b) and (F)(1)(c) appear to have typos in the numbering.

3. (G)(2)(b)(i), Test Method for Determination of Emissions-Operations with 

Emission Control Systems, refers to EPA Reference Methods 25, 25A or 25B, 

and should also include the full titles of the methods.

4. Please also add titles to the methods listed in (G)(2)(C)(i).

5. Section (G)(2)(h)(i), Test Method for Exempt Compound Concentration, refers to 

CARB Method 422,”Determination of Volatile Organic Compounds in Emissions 

from Stationary Sources” (January 22, 1987). That method was amended and 

accepted on December 13, 1991.

REFERENCES

1. “Suggested Control Measure for Automotive Coatings”, CARB, October 20, 2005.

2. “Identification of Performance Standards for Existing Stationary Sources”, CARB, 

April 22, 2010.

3. “Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly 

Coatings,” EPA-453/R-08-006, September 2008.

4. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies” 

(A.K.A., The Little Bluebook), EPA Region 9, August 21, 2001.

5. “Issues Relating to VOC Regulation Cutpoints, Deficiencies and Deviations”

(A.K.A., The Bluebook), EPA, 1988.

6. Rule 4612, “Motor Vehicle and Mobile Equipment Coating Operations”, 

SJVUAPCD, February 23, 2010.