UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

San Joaquin Valley Air Pollution Control District, Rule 4603, Surface Coating of 

Metal Parts and Products, Plastic Parts and Products and Pleasure Crafts

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

December, 2010
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RULE IDENTIFICATION -

Agency: San Joaquin Valley Air Pollution Control District

(SJVAPCD)

SIP Approved Rule: Rule 4603 – Surface Coating of Metal Parts and 

Products

Adopted –October 16, 2008

Submitted- December 23, 2008 

EPA Approved – January 19, 2010 (75 FR 2796)

Subject of this TSD: Rule 4603 – Surface Coating of Metal Parts and 

Products, Plastic Parts and Products and Pleasure 

Crafts

Amended – September 17, 2009

Submitted – May 17, 2010

RULE SUMMARY - SJVAPCD Rule 4603, Surface Coating of Metal Parts and 

Products, Plastic Parts and Products and Pleasure Crafts is a rule designed to 

limit volatile organic compound (VOC) emissions from facilities engaged in 

coating of metal parts and products, large appliances parts or products, and 

metal furniture and automotive/transportation and business machine plastic parts 

and products and pleasure craft. 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. Changes from the approved 

SIP rule include:

1. Added plastic parts and products, automotive/transportation and business 

machine plastic parts and products and pleasure crafts to the listing of 

coatings that this rule regulates.

2. Established VOC limits for several coating categories including Section 

5.4 for VOC limits for large appliance parts or products and metal furniture 

coating operations, Section 5.5 for VOC limits for plastic parts and 

products coating operations, Section 5.6 for VOC for 

automotive/transportation and business machine plastic parts and 

products coating operations and Section 5.7 for VOC for pleasure craft 

coating operations.

3. Provided exemptions for certain types of coatings in Section 4.0.

4. Included work practice standards for all coating operations covered by this 

rule in Section 5.9 and for cleaning solvents in Sections 5.10 and 5.11.

5. Established lower VOC content limits for cleaning solvents in Section 5.10.

6. Updated several definitions of terms used in the rule, which are consistent 

with the recommendations by the CTG
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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. RACT – EPA’s Control Technique Guidelines (CTGs) titled, “Control 

Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings”

(EPA-453/R-08-003, September 2008), “Control Techniques Guidelines for 

Large Appliance Coatings” (EPA-453/R-07-004, September 2007), “Control 

Techniques Guidelines for Metal Furniture Coatings” (EPA-453/R-07-005, 

September 2007), and other state and local rules for this category were 

used to help evaluate the RACT requirements of CAA §182(b)(2).

3. SIP Relaxation - Where previous versions of rules have been SIP approved, 

new submittals must comply with CAA §110(l) and §193 regarding SIP 

relaxations.

The monitoring, recordkeeping, reporting and other rule provisions are generally 

clear and otherwise fulfil CAA §110(a) (2) (A) enforceability requirements. The 

VOC limits and other requirements are as stringent as the 2007 and 2008 CTGs 

issued for this activity, so we believe the rule fulfils CAA §182(b) (2).RACT 

requirements. Lastly, the submitted rule is more stringent than the version 

previously approved into the SIP, so the submitted rule does not relax the SIP and 

complies with CAA §110(l) and §193. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 4603 

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

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

recommended for the next time the rule is amended. 

1. Please consider removing the exemption for stripping agents used for 

cured coatings, adhesives and ink in Section 4.12. See, for example, 

Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

451 in Section 303, and South Coast Air Quality Management District 

(SCAQMD) Rule 1107 in Section (c)(3). 

2. Please consider making the following formatting and editorial changes:

a. The AAMA reference in Section 3.42 should be 2604-05 and 2605-

05 as listed in the 2008 CTG.
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b. To avoid referencing Section 5.2 within Section 5.2, consider 

revising Section 5.2 to “Specialty Coating or Metal Parts and 

Products, except for Large Appliance or Products and Metal 

Furniture subject to Section 5.4.1 shall not apply to any metal part or 

product specialty coating with a VOC content in excess of the limits 

in Table 1.”

c. The Section following Subsection 5.12.10 should be 5.13, not 5.12.

d. In the definition of Dc in Section 5.8.4.1, please clarify that this factor 

is either a variable or a constant of 880 gram/liter.

e. Please also only use those ASTM methods that have been 

approved by the EPA in 40 CFR 60.17. ASTM D5478-98 and ASTM 

D5125-97 listed in Section 6.3.3 and ASTM D1613-96 listed in 

Section 6.3.5 are not approved.

f. We also recommend full titles all EPA-approved test methods be 

added to Section 6.3. For example, please see SCAQMD Rule 

1107 Section (e) (1) (A) and Placer County Air Pollution Control 

District (PCAPCD) Rule 245, Section 503.3. 

EPA ACTION - The rule largely fulfils the relevant CAA §110 and CAA part D 

requirements. EPA staff recommends full approval of Rule 4603 pursuant to CAA 

§110(k) (3) and §301(a). 

ATTACHMENTS -

1. SJVAPCD Rule 4603, Surface Coating of Metal Parts and Products, as 

submitted on May 17, 2010.

ADDITIONAL REFERENCES –

1. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts 

Coatings,” EPA-453/R-08-003, September 2008.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-

003_misc_metal_plasticparts_coating.pdf

2. “Control Techniques Guidelines for Large Appliance Coatings,” EPA453/R-07-004, September 2007.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r-07-

004_lg_appliance_coating.pdf

3. “Control Techniques Guidelines for Metal Furniture Coatings,” EPA-453/R07-005, September 2007.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r-07-

005_metal_furniture_coating.pdf

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

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

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

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