UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For
EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Santa Barbara County Air Pollution Control District , Rule 339, Motor Vehicle and Mobile Equipment Coating Operations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

September , 201 2- 2

-

Agency: Santa Barbara County Air Pollution Control District ( SB CAPC D)

Sip Approved Rule: Rule 339

- Motor Vehicle and Mobile Equipment Coating Operations
Revis ed – April 17, 1997 Submitted
– March 10, 1998 EPA Approved – October 13 , 1998 ( 63 FR 63410 )

Subject of this TSD: Rule 339

- Motor Vehicle and Mobile Equipment Coating Operations Adopt ed – June 19 , 2008 Submitted
– October 2 0 , 2008

RULE SUMMARY

- SB CAPCD Rule 339 , Motor Vehicle and Mobile Equipment Coating Operations , is a rule designed to limit volatile organic compound (VOC) emissions from facilities engaged in coating operations of motor vehicles and mobile equipment . 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 monitor ing requirements and test methods for determining various VOC content and emissions. In general,
the rule was changed to adopt the CARB Suggested Control Measure (SCM) for Automotive Coatings as approved by the Board on October 20, 2005. The sole
deviatio n is the exemption for pre

- sanding solvent to remove grease, wax and road
tar. 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- 3

- ( 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) requireme nt for enforceability.
2. Stringency
– EPA’s Control Technique Guidelines (CTGs) titled, “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts” (EPA

453/R

- 08

- 003, September 2008) and “Control Techniques Guidelines for Automobile and Light

- Duty Assembly Coatings” (EPA

- 453/R

- 08

- 006, September 2008 )
, 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(b)(2).
2. 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 monitoring, recordkeeping, reporting and other requirements generally ensure that Rule 339 can be enforced.

Stringency

- This rule does not need to fill RACT requirements because Santa Barbara attains the CAA ozone standards. Nonetheless, we believe Rule 339 implements RACT because it is as stringent as the 2008 CTG which has been issued for this activity with regard to coa ting of metal parts. We note that t
- butyl acetate is defined as a totally exempt VOC in section C. 42. Although the recordkeeping/reporting of t

- butyl acetate remains a requirement, EPA does not consider the lack of recordkeeping/reporting an obstacle to a pproving the rule because the recordkeeping provision is to determine if usage of t
- butyl acetate is- 4

-

significantly increasing as a result of its exemption as opposed to being used to determine a facility's compliance with the rule's specific VOC limits. Fu rther, t he State will continue to have a recordkeeping/reporting obligation for t
- butyl acetate 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 new submi ttal strengthens the previous SIP submittal and complies with CAA § 110(l) and § 193 regarding SIP relaxations. Although some coating categories are not comparable with the 1996 rule , the VOC limits of those that are comparable have all been reduced. Therefore, we propose to determine that our approval of the submittal would comply with the CAA §110(l) and § 193 regarding SIP relaxation because the submitted SIP rule ensures VOC emissions equivalent to or greater than those of the applicable SIP rule fo r the area, SBAPCD
Rule 339 as revised in 1997.

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. For clarity, p lease consider the following revisions to Section B, Exemptions:

a. In Section B.1, please add the requirement that a detailed log of automotive coating and coating components be maintained in accordance with Section F.6.
b. Section B.7 excludes the application of Sections D.2 through D.9 for painting of one vehicle per year, touch

- up coatings and lettering and striping . Consider changing this sections to, “The provisions of Sections D.2, D.7 and D.9 and Sections E and F shall not apply to the following , ” since the provisions of D.3, D.4, D.5, D.6 and D.8
sh ould still be implemented by the limited coating operations of Section B.7

. a

. , b

. and c

.- 5

- c. T he VOC content of the surface preparation in subsection B.8 is
limited to 780 grams per liter. Consider using a solvent with a VOC of 200 grams per liter or less as recommended by CARB.
2. For clarity, please add definitions for the following application methods listed in Section D.7: Dip Coating, Roller Coating and Spray Gun. 3. In order to be consistent, consider mov ing the last sentence of Section D.7.e to a new subsection D.7.f.
4. Please revise the following test method in consisten cies:

a. The EPA approved version of test method 1613 listed in Section E.2 is 1996

. b. In general, all EPA test methods listed in Section E.5 should include complete titles.

c. Please note that SCAQMD test method 318

- 95 listed in Section E.7 must be validated for any metal other than aluminium.
d. In Section E.8 t he correct date f or Method 432 is 1989, t he date for the EPA approved Method 422 is Septe mber 12, 1990 and t he date for the EPA approved SCAQMD Method 303

- 91 is August, 1996.

e. The SCAQMD method entitled in Section E.9 is Method TE.

EPA ACTION

- EPA staff recommends a full approval of Rule 339 pursuant to CAA §110(k) (4) and §301(a).

ATTACHMENT S

- 1. SBCAPCD Rule 339 , Surface Motor Vehicle and Mobile Equipment Coating Operations , as submitted on March 10 , 1998.
2. SBCAPCD Rule 339, Surface Motor Vehicle and Mobile Equipment Coating Operations, as submitted on October 20 , 2010

.- 6

-

ADDITIONAL REFERENCES

- 1. “Control Techniques Guidelines for Automobile and Light

- Duty Truck Assembly,” EPA

- 453/R

- 08

- 006, September 2008.
2. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings,” EPA

- 453/R

- 07

- 003, September 2008. 3. “Automotive Coatings Suggested Control Measure”, as approved by the Board on October 20,2005
4. “Issues Relating to VOC Regulation Cut points , Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.
5. “Guidance Document for Correcting C ommon VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.