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 Unified Air Pollution Control District, Rule 4612, Motor 

Vehicle and Mobile Equipment Coating Operations

Prepared by: Nicole Law

Reviewed by: Andrew Steckel

August 2011
2

RULE IDENTIFICATION 

Agency: San Joaquin Valley Unified Air Pollution Control 

District (SJVUAPCD)

SIP Approved Rule: Rule 4612- Motor Vehicle and Mobile Equipment 

Coating Operations – Phase II

Amended – September 20, 2007; Submitted – March 

7, 2008

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

Subject of this TSD: Rule 4612- Motor Vehicle and Mobile Equipment 

Coating Operations –

Amended – October 21, 2010; Submitted – April 5, 

2011

RULE SUMMARY –SJVUAPCD Rule 4612, Motor Vehicle and Mobile 

Equipment Coating Operations is a rule designed to limit volatile organic 

compound (VOC) emissions associated with coating of motor vehicles, mobile 

equipment, and related parts and components. The rule also limits VOC 

emissions from organic solvent cleaning, storage, and disposal associated with 

such operations and describes administrative requirements for maintaining 

records, recordkeeping, and test methods. Rule 4612 has been revised to 

remove redundant language and clarify the intent of requirements of the rule. 

Changes from the SIP approved Rule 4612 rule include:

1. Renamed the rule to remove the “Phase II” label, as that terminology is no 

longer used.

2. Edited definitions in Section 3. Definition of an “aerosol coating product” 

has been reworded and definitions for “operator” and “permanently 

labeled” have been added.

3. Edited an exemption in section 4.1.4. The exemption now clarifies that 

coatings applied to new motor vehicles or motor vehicle equipment during 

manufacture on an assembly line are regulated under District Rule 4602 

Motor Vehicle Assembly Coatings.

4. Updated coating limits in Section 5 to remove effective dates and expired 

limits. Also removed from this section are repetitive references to the

VOC emission control system option (former sections 5.3 and 5.4.2). New 

sections 5.7.3.1 and 5.7.3.2 were added to clarify requirements for HighVolume Low-Pressure spray equipment. Section 5.7.4 was edited to 

clarify what is required if a spray gun is used to comply with coating 

application methods.

5. Small additions were made to Section 6.0, Administrative Requirements. 

Section 6.4 clarifies that records need to be maintained on a daily basis 
3

and the quantity of each type of coating used is information that needs to 

be recorded. 

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) 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 – CARB’s Suggested Control Measure (SCM) titled, “Suggested 

Control Measure for Automotive Coatings,” SJVUAPCD’s 2009 RACT SIP 

Demonstration (April 16, 2009), “Preamble, Final Rule to Implement the 8-

hour Ozone National Ambient Air Quality Standard: (70 FR 71612 

November 29, 2005), Letter from William T. Hartnett to Regional Air 

Division Directors, “RACT Qs & As – Reasonable Available Control 

Technology (RACT) Questions and Answers” (May 18, 2006), 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 Staff Report which accompanies SJVUAPCD Rule 4612 includes a RACT 

Analysis. We concur with SJVUAPCD’s conclusion that Rule 4612 implements 

RACT for reasoning including:

- Rule 4612 closely resembles California Air Resources Board’s Suggested

Control Measure for Automotive Coatings. This is a recent guidance 

document from 2005 and we believe a reliable source for satisfying RACT. 

- SJVUAPCD, SCAQMD and the other large California nonattainment 

agencies generally have among the most stringent stationary source 

requirements nationwide, and we are not aware of other reasonably 

available technological or operational controls likely to significantly reduce 

additional emission from this activity.

However, we note that we do not agree with the complete analysis. Section VIII. B 

of the staff report states that two categories (precoat and TopcoatMetallic/Iridescent) are not as stringent as other district rules and Table 3 of the 

staff report depicts this also. We believe this is an incorrect analysis as discussed 
4

in our final rulemaking notice where the approval of the March 7, 2008 submittal 

was finalized (75 FR 2798, Response #4) on January 19, 2010. 

The submitted rule is as stringent as CARB’s 2005 SCM for Automotive Coatings

and fulfils RACT requirements. The recordkeeping and other requirements 

generally ensure that the submitted rule can be enforced. Lastly, the submitted 

rule revisions clarify and eliminates repetition in the version previously approved 

into the SIP, so the submitted rule does not relax the SIP and complies with 

§110(l) and §193. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 4612

sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – There 

are no additional recommendations for the next rule revision.

EPA ACTION -

The submitted revisions to Rule 4612 strengthen and clarify the SIP. The rule 

largely fulfils the relevant CAA §110 and part D requirements. EPA staff 

recommends approval of Rule 4612 pursuant to CAA §110(k)(3) and §301(a). 

REFERENCES -

1. SJVUAPCD Rule 4612, Motor Vehicle and Mobile Equipment Coating 

Operations – Phase II, as approved into the SIP on January 19, 2010.

2. SJVUAPCD Rule 4612, Motor Vehicle and Mobile Equipment Coating 

Operations, as submitted on April 5, 2011. 

3. “Suggested Control Measure for Automotive Coatings,” CARB, October 

2005.

http://www.arb.ca.gov/coatings/autorefin/scm/sreport/appenda.pdf

4. “Reasonably Available Control Technology (RACT) Demonstration for 

Ozone State Implementation Plans (SIP)” SJVAPCD, April 16, 2009.

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

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

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

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

(cover only).

7. Portions of the proposed post-1987 ozone and carbon monoxide policy 

that concern RACT, 52 FR 45044, November 24, 1987.

8. “State Implementation Plans, General Preamble for the Implementation of 

Title I of the Clean Air Amendments of 1990” 57 FR 13498, April 16, 1992.

9. “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient Air 

Quality Standard” 70 FR 71612; Nov. 29, 2005.

10. Letter from William T. Hartnett to Regional Air Division Directors, “RACT 

Qs & As – Reasonable Available Control Technology (RACT) Questions 

and Answers,” May 18, 2006.