UNITED STATES ENVIRONM E NTAL PROTE C TION AGENCY

Region IX AIR DIVISION

Technical Support D ocument

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 20122

Rule Identification

Agency: Mojave D esert Air Q uality Management District (MDAQMD)

SIP APPROVED RULE: Rule 1116

– Automotive Refinishing Operations Adopted

– April 26, 1999 Submitted

– July 2 3 , 1999 EPA Approved

- April 1 0 , 2000 (65 FR 18901)

Subject of this TSD: Rule 1116

– Automotive Refinishing Operations
A mend ed

- 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 section s of the earlier Rule

1116 . Section (A)

, General

, was expanded for clarity. In Section (B)

, eleven d efin i tions

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

, add s other requirements when using emission control s ystem s and

restrict s use of automotive c oating which contain Group II e xempt c ompounds

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

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

MDAQMD has expanded (D), Exemptions

, to include a ny coating that is :

1

. A pplied to motor vehicles d uring manufacture on an a ssembly l ine

, 2. A pplied 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 c oating training centers

.

MDAQMD has revised section (F)

, Monitoring and Records

, to make it consistent with
advances in a utomotive c oating o perations. Revisions include :

1. Add ed t argeted HAP c ompounds to the information required in (F)(1)(a)

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

, 3. Defin ed information to be included in (F)(1)(c)

, and
4. Lengthened the time records shall be retained fr om 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

,3

3. (G)(2)(h)(i) Exempt Compound Content.

EPA EVALUATION CRITERIA

– The following criteria and guidance documents were
used to evaluate the submitted R ule 1116

. Enforceability

– The Little Bluebook ( “ Guidance Document for Correcting Common
VOC & Other Rule D eficiencies, ” 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) an d 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

– W e have evaluated this proposed revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (RF P) 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, recordkeepi ng , reporting and other requirements ensure that Rule 1116
can be adequately enforced.

T he 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 ot her 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 m ethod 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).4

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 o f (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 M ethod for Determination of Emissions

- Operations with
Emis sion Control Systems

, refers to EPA Reference Methods 25, 25A or 25B

, and should also includ e the full titles of the m ethods

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

5. Section ( G)(2)(h)(i)

, Test Method for Exempt Compound C oncentration

, 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 Co atings ”, 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,” EP A

- 453/R

- 08

- 006, September 2008

. 4. “Guidance Document for Correcting Commo n VOC & Other Rule Deficiencies ” (A.K.A., The Little Bluebook)

, EPA Region 9, August 21

, 2001

. 5. “ Issues Relating to VOC Regulation Cutpoint s, Deficiencies and Deviations” (A.K.A., The Bluebook ) , EPA

, 1988

. 6. Rule 4612, “ Motor Vehicle and Mobile Eq uipment Coating Operations”, SJVUAPCD, February 23, 2010.