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, 2012
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Agency: Santa Barbara County Air Pollution Control District 

(SBCAPCD)

Sip Approved Rule: Rule 339 - Motor Vehicle and Mobile Equipment 

Coating Operations 

Revised – 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

Adopted – June 19, 2008

Submitted – October 20, 2008

RULE SUMMARY - SBCAPCD 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 monitoring 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 

deviation 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 
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(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. Stringency – EPA’s Control Technique Guidelines (CTGs) titled, “Control 

Techniques Guidelines for Miscellaneous Metal and Plastic Parts” (EPA453/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 coating 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 approving the rule

because the recordkeeping provision is to determine if usage of t-butyl acetate is 
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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. Further, the 

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 submittal 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 for 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, please 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 

should still be implemented by the limited coating operations of 

Section B.7. a., b. and c. 
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c. The 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 moving the last sentence of Section D.7.e 

to a new subsection D.7.f.

4. Please revise the following test method inconsistencies:

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 the correct date for Method 432 is 1989, the date for 

the EPA approved Method 422 is September 12, 1990 and the 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). 

ATTACHMENTS -

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. 
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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 Common VOC & Other Rule 

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