UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

Ventura County Air Pollution Control District, Rule 74.18, 

Motor Vehicle and Mobile Equipment Coating Operations

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

October, 2012
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Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP Approved Rule: Rule 74.18- Motor Vehicle and Mobile Equipment 

Coating Operations

Adopted – January 28, 1992

Amended – September 10, 1996

Submitted– March 3, 1997

EPA Approval – April 19, 2001 (66 FR 20122)

Prior Proposed Action: Rule 74.18- Motor Vehicle and Mobile Equipment 

Coating Operations

Amended – November 11, 2008

Submitted – March 17, 2009 

EPA Limited Approval-Limited Disapproval – December 

29, 2009 (74 FR 68759)

Subject of this TSD: Rule 74.18- Motor Vehicle and Mobile Equipment 

Coating Operations

Amended – November 11, 2008

Submitted – March 17, 2009

RULE SUMMARY - VCAPCD Rule 74.18, Motor Vehicle and Mobile Equipment 

Coating Operations, is a rule designed to limit reactive organic compound (ROC) 

emissions from the coatings and solvents associated with the refinishing of motor 

vehicles, mobile equipment and their associated parts and components. Section B, 

Requirements, includes a table that lists ROC limitations for coatings, primers, 

promoters and sealers prior to and effective on 1/1/2010 with a provision for using 

the lowest limit if a coating meets the definition of more than one category. This 

section also describes alternative compliance with add-on controls, application 

methods, prohibition of specification, prohibition of sales and possession, 
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manufacturer’s or re-packager’s compliance requirements, storage requirements and 

other requirements regarding toxins, spray and prep booths, labels and 

Occupational Safety and Health Association (OSHA) standards. Section C, 

Exemptions, lists types of coating exempt from the ROC limits, including aerosol 

coatings, coatings sold in small quantities, color coatings manufactured before 

January 1, 2009 until July 1, 2009, surface preparation solvents and cleaners 

solely for glass. Coating operations exempt from required practices include forgoing 

the use of spray booths for vehicles that don’t fit, touch-ups, engine compartment 

coating, vehicle interior coating, agricultural automotive coating operations and 

labeling of coating manufactured prior to July 1, 2008. Section D, Recordkeeping 

Requirements, documents requirements for recordkeeping of coatings and solvents, 

including maintenance of lists of all coatings at a site and monthly purchase records 

of coatings with ROC limits and monthly recycling or disposal records of cleaning 

solvents. In addition, this section has requirements for daily recording of key system 

operating and maintenance procedures where emissions control systems are used.

Section E, Test Methods, includes approved test methods for ROC content, exempt 

compound content, acid content, metallic content, hexavalent chromium content, 

lead or cadmium content, control and capture efficiency, transfer efficiency and 

high-volume, low pressure (HVLP) spray application equivalency. Section F, 

Violations, indicates that any violation of any provision of the rule is a violation of 

the rule. Section G, Definitions, defines all the relevant terms used in the rule.

Changes from the approved SIP rule include:

1. In section A, Applicability and Purpose, the rule’s purpose was added: to 

limit ROC emissions from coatings and solvents used in the automotive 

coating facilities.

2. In section B, Requirements, the following major changes were made:

a. Group I and II vehicle categories were discontinued. The ROC limits,

listed by the new coating categories, closely correspond to those in 
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the California Air Resources Board (CARB) Suggested Control 

Measure (SCM) For Automotive Coatings1in the Requirements

section. 

b. A clarification that the most restrictive limit be applied if a coating 

meets the definition of multiple categories was added.

c. The requirement of a detailed log of the sale of noncompliant 

coatings was added.

d. Alternate coating applications are now subject to approval by the 

APCO and the 65% required transfer efficiency was replaced with 

“transfer efficiency equivalent to, or higher than, one of the application 

methods listed in subsections B.4.a, B.4.b, B.4.c and B.4.d.”

e. The compliance statement requirements were expanded to include 

specific requirements for coating components, coating mixtures and 

cleaning solvents.

f. The solvent limit, as of January 1, 2010 was set at 25 grams per 

liter. 

g. The enforcement provision, prohibiting possession, was added.

h. The air toxic control measure, prohibiting the use of hexavalent 

chromium or cadmium in coatings, was added.

i. A new requirement, applying OSHA standards for spray coating, was

added.

3. Section C, Exemptions, was expanded to include exemptions of the sale of 

small containers of automotive coating, the use of certified “clean air 

solvents,” the use of non-aerosol glass cleaners, agricultural sources of air 

pollution, the possession, use, sale, supply or offer for sale through July 1, 

2009 of colored coatings manufactured before January 1, 2009 and the use 

of surface preparation cleaners. The required labeling of coating was 

exempted for coatings manufactured prior to July 1, 2008. The new 

 

1. CARB SCM For Automotive Coatings as approved by the Board on October 20, 2005
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exemption for preparation cleaning solvent in subsection C.12 exempts a 

compound containing 780 grams/liter ROC. However, this is limited to 20 

gallons per year which is below the allowable exemption of 55 gallons per 

year of high-Volatile Organic Compounds (VOC) coatings2. 

4. The Recordkeeping section, D, was changed from requiring daily usage 

records to requiring monthly purchase records. Monthly records for solvent 

disposal or recycling was added. A listing, which is maintained and available 

at all times, now includes the ROC Regulatory and Actual data for coatings 

used. 

5. Several methods in Test Method section E were changed: The ASTM 

method for determining ROC content was deleted, solvent pressure testing 

was deleted, spray gun cleaning solvent loss testing was deleted, and the 

following testing was added: tests for exempt ROC content, tests for 

cadmium and hexavalent chromium content, control and capture efficiency 

determination testing, HVLP equivalency testing and the use of alternate test 

methods if approved by the APCO, CARB and EPA. 

6. In section G, Definitions, some unnecessary definitions were deleted. Several 

new definitions were added including those for: aerosol coating, associated 

parts and components, automotive coating, automotive coating component, 

CARB, cleaning operations, clear coating, color coating, cured coating, 

electrostatic spray application, emission control system, EPA, janitorial 

cleaning, mobile equipment, multi-color coating, pretreatment coating, 

single-stage coating, solvent, spot repair, temporary protective coating, truck 

bed liner coating, underbody coating, uniform finish coating, VOC, VOC 

Actual for coatings, VOC Regulatory for coatings and water-reducible 

electrophoretic brake component coating. Several definitions were revised for 

clarification including: adhesion promoter, coating, exempt organic 

 

2. G.T. Helms memo on Exemption for Low-Use Coatings, August 10, 1990 
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compounds, high-voltage, low-pressure application, mobile equipment, motor 

vehicle, primer and primer sealer. 

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) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency – EPA’s Control Technique Guidelines (CTG) for, “Reduction for 

Volatile Organic Compound Emissions from Automobile Refinishing” (EPA450/3-88-009), dated October 1988, Alternate Control Techniques (ACT) 

Document: “Automotive Refinishing” (EPA-453/R-94-031) dated April 1994, 

CARB’s Air Toxic Control Measure (ACTM) 17 CA ADC § 93112, 

“Hexavalent Chromium and Cadmium Airborne Toxic Measure – Motor 

Vehicle and Mobile Equipment Coatings”, CARB’s SCM for Automotive 

Coatings (approved by the board on October, 2005) and other state and 

local rules for this category were used to help evaluate the RACT 

requirements of CAA §182(c)(1). 

3. Relaxation – 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).

Enforceability - The revised recordkeeping requirements reduce coating usage 

reporting from daily reporting of coatings used to a monthly coating purchase report. 

Although this is a change from the previous rule, we feel that enforceability is 

generally enhanced by the following changes to this rule:
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1. The mix ratios of the new water-born color coatings are inherently more exact 

that previous coating mixes.

2. The arbitrary averaging of clear and color coating ROC’s in the recordkeeping 

procedures has been eliminated.

3. ROC’s - actual and regulatory – are clearly defined with accurate calculations 

shown. All ROC limits have compliance dates.

4. The “Most Restrictive ROC Limit” statement in subsection B.2 precludes the 

arbitrary assignment of limits to coatings which may be assigned to more 

than one category. 

5. The alternative control systems and plans are subject to approval by the Air 

Pollution Control Officer, the position of which is defined. Additionally, the 

control efficiency is required to be at least 85%.

6. The new illegal possession provision in subsection B.10. increases 

enforceability.

7. The usage of all exempt surface preparation cleaners is enforced by a 

compliance plan which has detailed guidelines including lists of cleaners, 

labelling, VOC per container and vendor of cleaner. In addition, the usage is 

based on purchase records, which is a conservative approach.

8. The rule exemptions have been clarified to prevent uncertainty.

9. Recordkeeping requirements for solvents and coatings are clear and 

unambiguous, with clear and allowable recording timeframes. 

10. There are recommended test methods for twelve different coating factors and 

most non-EPA methods have full titles and approved version dates which 

improves enforceability. 

11. Rule violations are clearly defined as a failure to comply with any portion of 

the rule.

12. Definitions of various coatings like “metallic/iridescent topcoat” and 

“pretreatment coating” and operations, such as “mobile automotive coating 
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touch-up operations” and “spot repair” serve to clearly eliminate uncertainty 

about terms used in the limits table and to define exemptions.

13. Monthly reporting of solvent usage has been added to the rule.

Monitoring criteria is not explicitly addressed, although it is inferred that obtaining the 

ROC limits and transfer efficiency requires monitoring. Recordkeeping is overall 

analogous to that prescribed in CARB’s SCM and the EPA CTG. 

Stringency – Since Ventura County is a nonattainment area for ozone, the district is 

required to adopt all feasible measures to incorporate RACT requirements and to 

show progress in achieving these standards. We believe Rule 74.18 fulfills RACT 

requirements because the VOC limits are generally more stringent than the CTG for, 

“Reduction for Volatile Organic Compound Emissions from Automobile Refinishing” 

and are equivalent to the limits set forth in CARB’s SCM for Automotive Coatings. 

Rule 74.18 also places prohibitions and restrictions on the air toxic compounds 

Hexavalent chromium and Cadmium that were previously not regulated by this rule.

We note that t-butyl acetate (TBAc) is defined as an exempt organic compound in 

subsection G.16. Although the recordkeeping/reporting of TBAc remains a 

requirement pursuant to 40 CFR Part 51.100 (s)(5), EPA does not consider the 

lack of recordkeeping/reporting an obstacle to approving the rule because the 

recordkeeping provision is to determine if usage of TBAc is significantly increasing 

as a result of its exemption as opposed to being used to determine a facility's 

compliance with the rule's specific ROC limits. Further, the State will continue to 

have a recordkeeping/reporting obligation for TBAc unless and until EPA completes 

a rulemaking to revoke the requirement in 40 CFR 51.100(s), which we have been 

petitioned to do.

SIP Relaxation - The ROC limits for the new categories represent more stringent 

limits than the previous (September 10, 1996) version of the rule. 
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The adoption of the CARB 2001 Airborne Toxic Control Measure (ATCM 2001) 

which restricts the use of Hexavalent chromium and Cadmium is also viewed as 

advancement for this rule. In addition, solvents for preparation and cleaning are 

limited to 25 grams/liter ROC content. 

Although exemptions for automotive coatings sold in 0.5 fluid ounce containers, for 

“clean air solvents,” non-aerosol glass cleaners, agricultural pollution, preparation 

cleaning solvents and coatings manufactured prior to January 1, 2009 were added, 

they are likely to have limited emissions impact in Ventura County. VCAPCD 

projects emission reduction from the proposed new standards for coating and 

solvents to be 73 tons per year.

Therefore, we propose to determine that our approval of the submittal would comply 

with CAA §110(l) and §193 because the submitted SIP rule ensures VOC 

emissions equivalent to or greater than those of the applicable SIP rule for the 

area, VCAPCD Rule 74.18 as amended in 1999. 

EPA’s PREVIOUS PROPOSED ACTION -

On December 29, 2009 (see 69 FR 69298), we proposed a limited approvallimited disapproval of this rule because we determined that while it largely fulfilled 

the relevant CAA requirements regarding RACT, enforceability and rule relaxations, 

one rule deficiency was identified - the exclusion of recordkeeping or reporting for 

TBAc, as required by 40 CFR 51.100(s)(5).

However, we no longer believe that omitting the requirement for recordkeeping, 

emissions reporting, photochemical dispersion modeling and inventory requirements 

on the exempt compound TBAc is sufficient basis to disapprove this rule. As 

discussed in the previous section, “...TBAc will not be VOC for purposes of VOC 

emissions limitations or VOC content requirements”

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, which are the basis for 

compliance with this rule by a facility. In addition, the State will continue to 

assume the responsibility for the reporting, modeling and inventory requirements.

 

3. 40 CFR 51.100(s)(5)
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In response to this prior proposed limited disapproval action, Lyondell Chemical 

Company commented that they encouraged the EPA to reconsider the limited 

disapproval of this rule because the TBAc reporting and recordkeeping requirements 

“are burdensome, arbitrary, contrary to the goals of the Clean Air Act (CAA), and 

should be rescinded.”

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Lyondell, as the developer and producer of TBAc, also 

indicated that it has and continues to provide TBAc sales data to the EPA and that 

other reported emissions data would be inaccurate. The arguments were convincing 

enough to engage EPA in a discussion of the merits of this provision and to 

reverse our proposed decision on this rule. 40 CFR 51.100(s)(5), to date, remains 

unchanged but we no longer consider it an adequate justification for disapproval of 

VCAPCD Rule 74.18. 

 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

The following revisions are not currently the basis for rule disapproval, but are 

recommended or required for the next time the rule is amended:

1. In Section A, Applicability and Purpose, please include “specifies” as an 

activity to which this rule applies: “The provisions of this rule apply to any 

person who manufactures, distributes, supplies, sells, offers for sale, applies, 

solicits the use of or specifies automotive coatings for motor vehicles...” This 

is stated in subsection B.5. but was inadvertently removed from this section.

2. In Section B, Requirements, please consider making the following changes:

a. In subsection B.6.a. , please correct the acronym APCO.

b. In subsection B.11. , please consider adding the reference to the Air 

Toxic Control Measure (ATCM) (Title 17 CA ADC § 93112) for 

Hexavalent Chromium and Cadmium Airborne Toxic Measure from 

Motor Vehicle and Mobile Equipment Coatings.

 

4. January 27, 2010 letter Re: Comments on the California State Implementation Plan, South 

Coast Air Quality Management District and Ventura County Pollution Control District (EPA-R09-

OAR-2009-0754, sent by Dan Pourreau, Project Manager of Lyondell Chemical Company to EPA. 
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c. In subsection B.14. , please define the acronym OSHA (Occupational 

Safety and Health Administration) and this first reference to CCR 

(California Code of Regulation) and remove that same definition from

subsection C.2.

3. In Section C:

a. The agriculture exemption in subsection C.10 is not in the SIPapproved version of the rule. Moreover, this exemption is not included 

in the SCM, San Joaquin Valley Rule 4612 or South Coast Rule 

1151. Please remove this exemption or justify why treatment of 

agricultural sources differently from other potentially affected sources 

is appropriate and complies with CAA § 110(l).

b. The VOC content of the surface preparation in subsection C.12.c is 

6.51 lb. per gal which is equivalent to 780 grams per liter. Consider 

using a solvent with a VOC of 200 grams per liter or less as 

recommended by CARB.

4. In section D, please provide a separate daily recordkeeping schedule for the 

surface preparation cleaner described in subsection C.12 as there is a yearly 

cap on this solvent, as prescribed in subsection C.12.b. Also, similar to 

Antelope Valley Air Quality Management District (AVAQMD) rule 1151, 

consider specific recordkeeping for methylene chloride (MeCl) in response to 

40 CFR 63 Subpart HHHHHH –National Emission Standards for Hazardous 

Air Pollutants (NESHAP): Paint Stripping and Miscellaneous Surface Coating 

Operations at Area Sources.

5. To aid tracking and inspection, Bay Area Air Quality Management District 

(BAAQMD) Regulation 8, Rule 45, Motor Vehicle and Mobile Equipment 

Coating Operations, requires any person for whom mobile refinishing 

operations are conducted at least five times in any one-year period or for 

which 25 vehicles were refinished in any one-year period to keep records

indicating the following: the name, address, phone number, retail tax license 
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number, and valid District registration number of each mobile refinishing 

operator utilized; the date(s) each mobile refinisher engaged in mobile 

refinishing operations; and the number(s) of vehicles refinished by each 

mobile refinisher on the date(s). Please consider a similar provision to 

strengthen the enforceability of Rule 74.18.

6. For consistency, please consider the following revisions to section E:

a. In subsection E.4, please add the date of the EPA approved version 

of SCAQMD method 311-91, “Determination of Weight Percent 

Elemental Metal in Coatings by Spectrographic Method”, June 1, 

1991.

b. The ASTM reference in subsection E.5 should indicate the date 

(2010) and the title: “Standard Test Method for Low Concentrations 

of Chromium by Atomic Absorption Spectroscopy.” 

c. The ASTM reference in subsection E.6 should indicate the date 

(2010) and the title: “Standard Test Method for Low Concentrations 

of Lead, Cadmium, and Cobalt in Paint by Atomic Absorption 

Spectroscopy.”

EPA ACTION - Rule 74.18 fulfills the relevant CAA §110 and part D requirements. 

Therefore, EPA staff recommends a full approval of Rule 74.18 pursuant to CAA 

§110(k) (3) and §301(a). This analysis and recommendation replaces the TSD 

prepared in support of our 12/29/09 proposed action (74 FR 68759). 

ATTACHMENTS -

1. VCAPCD 74.18, Motor Vehicle and Mobile Equipment Coating Operations, as 

amended on September 10, 1996.
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2. VCAPCD 74.18, Motor Vehicle and Mobile Equipment Coating Operations, as 

submitted on March 17, 2009. 

ADDITIONAL REFERENCES –

1. EPA’s Control Technique Guidelines (CTG), “Control Technique 

Guidelines for Emissions from Automobile Refinishing” (EPA-450/3-

88-009), October 1988.

2. Alternative Control Techniques (ACT) Document, “Automotive 

Refinishing” (EPA-453/R-94-031), April 2004.

3. Air Toxic Control Measure (ATCM) (Title 17 CA ADC § 93112) for 

Hexavalent Chromium and Cadmium Airborne Toxic Measure from 

Motor Vehicle and Mobile Equipment Coatings.

4. AVAQMD) rule 1151, Motor Vehicle and Mobile Equipment Coating 

Operations, amended June 19, 2012.

5. CARB Suggested Control Measure (SCM) for “Automotive Coatings”

as approved by the Board on October 20, 2005.

6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

7. “Guidance Document for Correcting Common VOC & Other Rule 

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

2001.