1 Final Staff Report with Appendices for Proposed Amendments to Ru le 4612 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operati ons)

October 21, 2010

Prepared by: Anna Myers, Air Quality Specialist

Reviewed by: Colette Kincaid, Senior AQ Specialist Dustin Brown, Senior AQ Engineer Koshoua Thao, Senior AQ Specialist Joven Nazareno, Senior AQ Engineer Ryan Hayashi, Compliance Supervisor Michael Carrera, Compliance Manager George Heinen, Rule Development Supervisor Errol Villegas, Strategies and Incentives Program Manager Samir Sheikh, Director of Strategies and Incentive s

I. SUMMARY

The source category of Motor Vehicle and Mobile Equ ipment Coating Operations currently includes operations that apply, supply, s ell, offer for sale, or solicit the application of VOC-containing coatings used in the finishing or refinishing of vehicles and equipment, and their parts and components. Thi s category also includes the organic solvent cleaning, and the storage and dispo sal of all solvents and waste solvent materials associated with such coating operations. Rule 4602 (Motor Vehicle and Mobile Equipment Operations) was adopted in 1991. In September 2006, Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operati ons – Phase II) was adopted to supersede Rule 4602 to incorporate the elements of the Air Resources Board (ARB) Suggested Control Measure (SCM) for this source cat egory with a compliance date of January 2009. However, since the implementation of current rule language for Rule 4612, it has been determined that specific sections need updating in order to remove redundant language, clarify the intent of the secti on, and align the rule with requirements previously required.

The purpose of this rule-amendment project is to fu lfill the commitment in the San Joaquin Valley Air Pollution Control District (Dist rict) 2007 Eight-Hour Ozone Plan (Ozone Plan) and to update Rule 4612 by removing re dundant language and clarify the intent of requirements of the rule. The District O zone Plan committed staff to explore the possibility of reducing emissions from this sou rce category by use of incentive funding. Staff investigated the possible incentive funds and emissions potentially

reduced from use of such funds. Staff has conclude d that there are currently no specificSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

2 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 funds available and that because operators are curr ently using all possible measures to reduce emissions, there are not further feasible op portunities to reduce emissions through incentivized activities. The proposed rule amendments will not affect the meaning, scope of, or prohibitions contained in cur rent rule language.

A. Reasons for Rule Development and Implementation

The California Air Resources Board (ARB) and the Un ited States Environmental Protection Agency (EPA) classified the San Joaquin Valley Air Basin (Valley) as severe

and extreme non-attainment for the state and federa l ozone standards, respectively. In accordance with Federal Clean Air Act (CAA) require ments for non-attainment areas, the District adopted the Ozone Plan to establish th e strategy for attaining the eight-hour ozone standards. The ozone attainment strategy of the Ozone Plan is comprised of regulatory and incentive-based measures to reduce e missions of nitrogen oxides and volatile organic compounds (VOC), a precursor of gr ound-level ozone. The following table is a summary of Ozone Plan Commitments.

Table 1 - Ozone Plan Commitments Subject Reference Requirement

BARCT CH&SC 40919(a)(3)

2007 Ozone Plan Ozone attainment plan should provide for best available retrofit technology (BARCT) for existing permitted sources.

Deadlines Ozone Plan Adoption of rule amendments by Plan committed deadline.

Feasible

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all feasible control

measures."

RACT CAA 182(b)(2) and

182(f) Ozone attainment plans shall assure that reasonably available control technology (RACT) for oxides of n itrogen (NOx) and volatile organic compounds (VOC) is in us e at sources and on source categories at or above the RA CT

threshold.

Reductions Ozone Plan Emission reductions will be calculated during the r ule development process.

Timeline CAA Section 172(c)(1) Ozone attainment plans shall implement control meas ures as expeditiously as practicable, and provide for at tainment.

B. Climate Change

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, multi-year program to reduce greenhouse gas (GHG) e missions in California, with the goal of restoring emissions to 1990 levels by 2020. In the coming years, the ARB and the Legislature will be developing policies and pro grams to implement Assembly Bill 32 (AB 32). There are many win-win strategies that ca n reduce both GHG and criteria/ toxic pollutant emissions. However, the District’s primary mission remains to achieveSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

3 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 attainment with air quality standards to protect pu blic health. Therefore, when situations

that involve tradeoffs between GHG and criteria or toxic pollutants arise, the District will give precedence to reducing criteria or toxic pollu tant emissions due to the more immediate public health concerns associated with su ch pollutants.

C. Description of Project

The 2007 Ozone Plan committed staff to research the possibility of gaining more emission reductions from this source category throu gh the use of incentive funding.

The Ozone Plan also indicates that this rule curren tly encompasses the most stringent coating VOC content limits for this source category . Based on measures taken by industry to comply with these standards, staff has determined that there are no

additional emission reductions available from this source category, even given the addition of incentive funding. The proposed amendm ents do not change the meaning of the rule or create more stringent enforcement of em ission control standards. As such, this rule-amending project is not expected to reduc e VOC emissions.

D. Rule Amendment Process

The draft rule and draft staff report were publishe d for a 30-day public commenting period with no public workshop in July 2010. No co mments were received as a result of the commenting period. The notice of the public he aring for the proposed amendments was published in general circulation newspapers in each of the eight Valley counties,

and was made available for review on the District w ebsite. A summary of the comments received and District responses are in Appendix A o f the Final Staff Report.

II. DISCUSSION

A. Current Regulation

The purpose of Rule 4612 is to limit VOC emissions from coatings associated with the coatings of motor vehicles, mobile equipment, and a ssociated parts and components, and to reduce the VOC emissions from the organic so lvent cleaning, storage, and disposal associated with such operations. Rule 461 2 applies to any person who supplies, sells, offers for sale, manufacturer s, or distributes any automotive coating for use within the District, as well as any person who uses, applies, or solicits the use or application of any automotive coating within the Di strict.

Rule 4612 limits VOC emissions by limiting the VOC content of coatings used for coating motor vehicles and mobile equipment and ass ociated organic cleaning solvents. In lieu of complying with VOC content limits, opera tors have the option to operate an APCO-approved VOC emission control system, subject to rule requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

4 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 B. Proposed Amendments

Title The title would be amended to remove “Phase II”, wh ich is no longer relevant since there is no longer a “Phase I” rule.

Section 3.0 – Definitions Section 3.0 would be amended to define “operator” a nd “permanent label”.

Section 4.0 – Exemptions Section 4.1.4 would be amended to clarify the inten t of this exemption. Current language exempts facilities that operate automotive assembly lines, which is a separate source category covered by Rule 4602 (Motor Vehicle Assembly Coatings). However, Rule 4602 applies only to VOC-containing coatings a pplied to new automobiles, light-duty trucks, heavier vehicles, and other parts coated al ong with these bodies or body parts during the assembly process.

In 2008 EPA promulgated the Control Techniques Guid elines (CTG) for Automobile and Light-Duty Truck Assembly Coatings. The CTG provid es control recommendations for reducing VOC emissions stemming from the use of coa tings in automobile and lightduty truck assembly coating operations. The CTG fu rther states:

The automobile and light-duty truck assembly coatin gs product category under section 183(e) of the CAA includes primary co atings that are applied to new automobiles or new light-duty truck bodies, or body parts for new automobiles or new light-duty trucks, and o ther parts that are coating along with these bodies or body parts. The category also includes additional coatings applied during the vehicle asse mbly process. Automobile and light-duty truck assembly coatings m ost commonly are applied at automobile or light-duty truck assembly plants. However, this 183 (e) category also includes coatings used in fac ilities that perform these coating operations on a contractual basis.

Conversations with the author of the CTG verified t hat intended applicable facilities would be manufacturers of new automobiles, not “upf itting” or refinishing operations, even if they operate on an assembly line. District staff also contacted ARB staff to clarify SCM language regarding the exemption for as sembly operations, as stated in

current District Rule 4612 Section 4.1.4. Conversa tions with ARB staff has led District staff to conclude that the exemption in Section 4.1 .4 was intended to exempt new vehicle manufacturers, not upfitting and resurfacin g operations.

Upfitting a vehicle involves the operator receiving a vehicle that is registered with the state and has a vehicle identification number (VIN) . The operator will modify that vehicle to specifications provided by the buyer/own er, and then re-register theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

5 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 completed vehicle with the new weight information, while leaving the VIN number unchanged.

There is one motor vehicle upfitting operation in t he Valley that operates using an assembly line. As current rule language is written , this upfitting automotive assembly line and coating operation would be exempt from Rul e 4612, and as explained above, is not subject to Rule 4602. As currently written, th e operation would, by default, become subject to District Rule 4603 (Surface Coating of M etal Parts and Products, Plastic Parts and Products, and Pleasure Crafts), which is not th e District’s intent. District staff is recommending amending the exemption in Section 4.1. 4 to clarify that the assembly line exemption applies to the assembly of new automobile s subject to District Rule 4602 and not refinishing or upfitting operations. Therefore , facilities that operate an assembly line for refinishing or upfitting that were previously s ubject to the motor vehicle and mobile equipment coating regulation will remain subject to the motor vehicle and mobile equipment regulation.

Section 5.0 – Requirements

Section 5.3 would be amended to remove redundant la nguage.

Section 5.7 Coating Application Methods Sections 5.7.3.1 and 5.7.3.2 would be added to spec ify HVLP requirements that were previously in Rule 4602 but were not carried over t o Rule 4612 during the rule amendment project to adopt Rule 4612. This languag e also more closely mirrors the language in the ARB SCM, of which the amendments we re originally based on. The additional language does not change the meaning of current language but instead

clarifies it.

Section 6.0 – Administrative Requirements

Section 6.3 would be amended to remove redundant la nguage.

Section 6.4 (Recordkeeping Requirements for Coating s) would be updated to include language specifying that records be kept daily, as was the requirement in the previous rule. This language had not been carried over to t his new rule from Rule 4602 but was requested by EPA for consistency with other air dis tricts.

C. Incentives

As committed in the District 2007 Ozone Plan, staff researched the possibility of reducing emissions from this source category throug h use of incentive funding. District staff determined there are approximately 126 facili ties in the Valley currently subject to the motor vehicle and mobile equipment rule. Conve rsations with the Compliance Department have confirmed that facilities have opte d to comply with the new VOC standards that became effective on January 1, 2010, by using water-based coatingsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

6 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 rather than coating with exempt solvents or install ing costly capture and control
systems.

The November 2008 Ventura County Air Pollution Cont rol District (VCAPCD) Staff Report for Rule 74.18 (Motor Vehicle and Mobile Equ ipment Coating Operation) states that the new [water-based] color coats are performi ng at levels equal to or superior than the solvent-based versions. The report continues t o say that the upgrades necessary for spray booths consist of adding fans or air move ment equipment to accelerate the drying of the waterborne coatings, and these change s can be made over the time of a

weekend.

Rule 4612 new VOC content limits became effective J anuary 1, 2010 and Valley operators have already made any necessary adjustmen ts to ensure compliance with the new limits and requirements. Rule 4612 has the mos t stringent VOC content limits for this source category and the most stringent solvent cleaning VOC provisions for this source category. Staff researched incentive fundin g possibilities and have determined

that there are no incentive funds available for thi s source category at this time.

The intent of incentive funding from the District t o Valley facilities is to provide funding

that would result in further reductions of emission s. At this time, there are no alternative

methods to further reduce VOC emissions from this s ource category. Operators are using the most current technology and the lowest VO C content coatings technologically feasible. However, District Staff welcome suggesti ons operators or stakeholders may have regarding opportunities for potential incentiv e programs, should such funds

become available in the future.

III. EMISSION REDUCTIONS ANALYSIS

According to the 2007 Ozone Plan, total VOC emissio ns from sources subject to Rule 4612 are estimated to be 1.54 tons per day in 2011. The 2007 Ozone plan called for

use of incentives to further reduce emissions from this source category. Currently there

are no incentive funds available for this source ca tegory. Additionally, the proposed rule amendments will not affect the meaning, scope of, o r prohibitions contained in current rule language. As such, no emission reductions are expected from this rule amending project.

IV. COST EFFECTIVENESS ANALYSIS

Pursuant to CH&SC Section 40920.6(a), the District is required to analyze the cost

effectiveness of new rules or rule amendments that implement Best Available Retrofit Control Technology (BARCT) or all feasible measure. Current Rule 4612 alreadySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

7 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 implements BARCT. No new emission control requirem ents are proposed. As such, this project is not subject to the cost effectivene ss analysis mandate.

V. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC Section 40728.5 (a), an assessmen t of the socioeconomic impacts is not required for any rule or regulation that onl y adopts a requirement that is substantially similar to, or is required by state o r federal statute, regulation, or applicable formal guidance, such as a federal CTG. Proposed a mendments to Rule 4612 are substantially similar to the ARB SCM for automotive coatings therefore there is no new inputs to operators so a socioeconomic impact analy sis is not required.

VI. RULE CONSISTENCY ANALYSIS

CH&SC, Section 40727.2, requires District staff to prepare a rule consistency analysis for Rule 4612 that compares the elements of amendments with the corresponding elements of other District rules, federal regulations and gu idelines that apply to the same source category or type of equipment. Preliminary analysi s has indicated that none of the proposed requirements of this rule would conflict w ith federal rules, regulations, or policies covering similar stationary sources. Dist rict staff has prepared a rule consistency analysis, please refer to Appendix B fo r this analysis.

VII. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Ac t (CEQA), District staff investigated the likely environmental impacts of the proposed amendm ents to Rule 4612. Based on the lack of evidence to the contrary, District staff ha s concluded that the proposed amendments to the rule will not have any significan t adverse effects on the environment. Staff recommends filing a Notice of E xemption under the provisions of Public Resource Code 15061 (b) (3).

VIII. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RAC T) ANALYSIS

RACT Discussion The Clean Air Act (CAA) Section 182(b)(2) states th at ozone attainment plans shall assure that RACT for volatile organic compounds (VO C) is applied at certain sources. District Rule 4612 is a VOC rule, therefore underwe nt a RACT analysis during this ruleamending project. A RACT analysis requires an exam ination of a rule against Federal rules, regulations, and technology guidelines as we ll as comparing it against rules from

other air districts in California.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

8 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 District staff compared emission limits, optional c ontrol requirements, and work practice standards in District Rule 4612 to comparable requi rements in rules from the other Air

Districts in California nonattainment areas. Based on that analysis, District staff has

concluded that District Rule 4612 satisfies RACT fo r automotive coating operations.

A. Comparison with Federal Rules and Regulations

EPA – Control Technique Guidelines (CTG)

1. EPA-450/2-76-028 1976/11 Control of Volatile Organic Emissions from Existing Stationary Sources - Volume I: Control Methods for Surface Coating Operations The CTG applies to surface coating operations locat ed in marginal, moderate, serious or severe ozone nonattainment areas that has the po tential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 1 0 tons/year of VOC for extreme

ozone nonattainment areas. This CTG will not be co mpared to District Rule 4612 since the source category (Motor Vehicle and Mobile Equip ment Coating) is addressed in

another CTG: EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Co ating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (See di scussion below).

2. EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks The CTG applies to motor vehicle surface coating op erations located in marginal, moderate, serious or severe ozone nonattainment are as that has the potential to emit greater than or equal to 25 tons/year of VOC, and e qual to greater than 10 tons/year of

VOC for extreme ozone nonattainment areas. The tab le below identifies the CTG requirements and how Rule 4612 compares to the auto mobile and light-duty truck coating requirements.

Table 2 - Rule and CTG Comparison
Coating Type CTG (lb/gal) Rule 4612 (lb/gal)

Prime 2.8 2.1
Topcoat 4.2 2.1
Final Repair Topcoat 5.5 2.1

3. EPA-453/R-08-006 2008/09 Control Techniques Guidelines for Automobile and LightDuty Truck Assembly Coatings The CTG applies to vehicle assembly coating operati ons located in marginal, moderate,

serious or severe ozone nonattainment areas that ha s the potential to emit greater than or equal to 25 tons/year of VOC, and equal to great er than 10 tons/year of VOC forSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

9 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 extreme ozone nonattainment areas. There are no ve hicle assembly plants in the District and such operations would fall under Rule 4602 therefore, this CTG will not be

examined.

EPA - Alternative Control Technology (ACT)

EPA-453/R-94-017 1994/02 Alternative Control Techniques Document - Surface Coating of Automotive/Transportation and Business M achine Plastic Parts The ACT applies to the coating of plastic parts for the automotive industry, business machines, and other miscellaneous plastic parts. T he ACT identifies an automotive coating work practice standards, VOC content limits , application methods, and add-on

control efficiencies based on California air distri ct rules as of 1994. Since SJVAPCD Rule 4612 is at least as stringent overall compared to other districts (see analysis below in Section III), a detailed evaluation of the ACT i s not necessary.

Standards of Performance for New Stationary Sources (NSPS) 40 CFR 60 Subpart MM (Standards of Performance for Automobile and Light Duty Truck Surface Coating Operations) applies to assemb ly plant coatings. There are no vehicle assembly plants in the Distric t; therefore, this NSPS will not be

examined.

National Emission Standards for Hazardous Air Pollu tants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has de legated the authority to implement NESHAP requirements to the District, NESH APs and MACTs promulgated by EPA are usually incorporated by reference into D istrict Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is imp ortant to mention that the District implements NESHAPs and MACTs by incorporating the e mission standards as conditions of the Permits to Operate issued to affe cted sources.

40 CFR 63 Subpart IIII (National Emission Standards for HAPs: Surface Coating of Automobiles and Light-Duty Trucks) The requirements in this subpart are not directly c omparable to the District Rule 4612

limits. The NESHAP HAP emission limits which are e xpressed in terms of % HAP, HAP emission concentration, and mass (kg) of HAP per ma ss (kg) of solids are not directly comparable to the coatings VOC limit which is expre ssed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs, and some VO Cs may be HAPs; therefore,

there is no direct correlation between the NESHAP l imits versus District Rule 4612 VOC

limits.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

10 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 B. Comparison with Other California Non-Attainment Areas

District staff compared District Rule 4612 with the rules of other California ozone nonattainment air districts’ rules (listed below) a uto coating operations. The results of the analysis are discussed below.

• South Coast Air Quality Management District (SCAQM D) Rule 1151 - Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Oper ations (Amended December 2, 2005)

• Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 45 – Motor Vehicle and Mobile Equipment Coating Operations (Am ended January 6, 1999)

• Sacramento Metropolitan Air Quality Management Dis trict (SMAQMD) Rule 459 - Automotive, Truck and Heavy Equipment Refinishing O perations) (Amended

• October 2, 1997)

• Ventura County Air Pollution Control District (VCA PCD) Rule 74.18 - Motor Vehicle and Mobile Equipment Coating Operations (Amended Se ptember 10, 1996)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

11 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 Table 3 - Rule Comparisons (g/l VOC)

Coating Category Bay Area (Rule 8-45) South Coast

(Rule 1151) Sac Metro

(Rule 459) Ventura

(Rule 74.18) SJVAPCD

(Rule 4612)

Adhesion Promoter

Plastic Parts 540
Camouflage 420 420 420 340
Clear Coating 250
Color Coating 540 685 420

Pretreatment 780 750 780 780 660

Precoat 580 600 660

Primer 250 250 250

Primer Sealer 340 340 420 340 250

Primer Surfacer 250 250 250 250

Single Stage Coating (not primer or multicolor) 340
Topcoat - General 420 340 420 340 250
Topcoat - Metallic/ Iridescent 520 340 520 520 420

Topcoat - Metallic/ Iridescent (spot repair) 420 420
Topcoat - Multicolored 540 685 420
Topcoat - Multistage 340 540 340 340

Topcoat - Multistage (spot repair) 420 340 Water-Based Temporary

Transit 420 250

Coating Category Bay Area (Rule 8-45) South Coast

(Rule 1151) Sac Metro

(Rule 459) Ventura

(Rule 74.18) SJVAPCD

(Rule 4612)
Temporary Protective Coating 60 60 60

Truck Bed Liner 310
Underbody Coating 540 430
Uniform Finish Coating 540

Other 250

Application Method Bay Area (Rule 8-45) South Coast

(Rule 1151) Sac Metro

(Rule 459) Ventura

(Rule 74.18) SJVAPCD

(Rule 4612)
HVLP Spray X

Transfer Efficiency

Minimum 65% 65% APCO/EPA Approved 65% 65%

Add-on Control Efficiency Bay Area (Rule 8-45) South Coast

(Rule 1151) Sac Metro

(Rule 459) Ventura

(Rule 74.18) SJVAPCD

(Rule 4612)

Control 85%

Overall Control Equiv to compliant coating

emissions Equiv to

compliant coating

emissions 85% 85% by wt 85 % and Equiv to compliant coating

emissionsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4612 October 21, 2010

12 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 Table 3 - Rule Comparisons (g/l VOC) continued

Solvents Bay Area (Rule 8-45) South Coast

(Rule 1151) Sac Metro

(Rule 459) Ventura

(Rule 74.18) SJVAPCD

(Rule 4612)
Product Cleaning (General) 72 25 72 200 25

Repair and Maintenance Cleaning 25 72 200 25

Cleaning of Application Equipment 25 72 200 25

As shown in the table above, SJVAPCD Rule 4612 is a s stringent as or more stringent than other districts in all categories except for t wo categories (precoat and Topcoat - Metallic/Iridescent). Since the overwhelmingly maj ority of coating categories are as stringent as or more stringent than other districts , Overall SJVAPCD Rule 4612 is at least as stringent as Bay Area Rule 8-45, South Coa st Rule 1151, Sac Metro Rule 459,

and Ventura Rule 74.18.

RACT Analysis Conclusion After careful evaluation of federal rules and regul ations as well as prohibitory rules in other California nonattainment areas, District staf f concludes that District Rule 4612 satisfies RACT for motor vehicle and mobile equipme nt coating operations.

IX. REFERENCES

1. ARB. “Suggested Control Measure for Automotive Coatings as Approved by the Board on October 20, 2005”. 2. EPA. “Control Techniques Guidelines (CTG) for A utomobile and Light-Duty Truck Assembly Coatings”. 2008.

3. SJVAPCD. “Ozone Plan”. 2007. 4. Ventura County APCD. “Final Staff Report Revisi ons to Rule 74.18, Motor Vehicle and Mobile Equipment Coating Operation”. November 11, 2008.