+-----+-----------------+---------------------------------------------+
|     | > **William     | To: Ray Vogel/RTP/USEPA/US@EPA              |
|     | > Thompson      |                                             |
|     | > \<WThomps     | cc: Mohsen Nazemi \<MNazemi1@aqmd.gov\>,    |
|     | on@aqmd.gov\>** | Jay Chen \<JChen@aqmd.gov\>, Edwin Pupka    |
|     | >               | \<EPupka@aqmd.gov\>, Ben Shaw               |
|     | > 07/23/2003    | \<BShaw@aqmd.gov\>                          |
|     | > 01:47 PM      |                                             |
|     |                 | Subject: RE: FW: End of Area Source         |
|     |                 | deferrals - Informal comments               |
+-----+-----------------+---------------------------------------------+

> Hi Mr. Vogel,
>
> I\'ve checked with SCAQMD\'s compliance managers and have the
> following information to add:
>
> A\) Drycleaners are typically inspected about every 18 months and,
> thanks to newer technologies, emissions compliance rates are about
> 90%. Overall compliance rates for this source category are lower
> (about 60%) due to record-keeping infractions. Most dry cleaner owners
> have communications concerns so much effort is expended in outreach to
> associations and trade groups. So far, this has met with modest
> success. This is also a major concern with eliminating the Title V
> deferral for this area source. The added complexity of a Title V
> permit would certainly overwhelm a high proportion of these
> owner/operators resulting in frustration and non-compliance without a
> corresponding air quality benefit. Also please note that the SCAQMD
> adopted an amendment to it\'s rules that eliminate the use of
> perchloroethylene in the coming years. This rule is
> [http://www.aqmd.gov/rules/html/r1421.html]{.underline} .
>
> B\) Degreasers using HAPs are quickly being phased out in favor of
> aqueous cleaners. There are only a few left in the areas regulated by
> AQMD and these will likely be retired soon. Needless to say, these are
> inspected annually and compliance rates are high (\> 80%).
>
> C\) There are 7 ETO sterilizers in operation commercially. These are
> all inspected, at a minimum, annually. As in the case of degreasers
> using HAPs, compliance rates, due to the small number of facilities
> and the nature of these sources, approaches 100%. These sources are
> subject to SCAQMD Rule 1405
> [http://www.aqmd.gov/rules/html/r1405.html]{.underline}
>
> D\) There are two secondary lead facilities in our area - both have
> Title V permits already.
>
> E\) There are a handful of secondary aluminum facilities. These are
> all inspected annually and compliance rates are satisfactory. Getting
> an accurate source test can be problematic however, so we continue to
> make these facilities a priority.
>
> F\) The SCAQMD regulates about 190 chrome plating facilities and these
> are inspected at least annually. Many are inspected more frequently.
> SCAQMD rule 1469
> [http://www.aqmd.gov/rules/html/r1469.html]{.underline} applies to
> these facilities. This rule has technology and risk-based requirements
> that result in a rule, that SCAQMD believes, is more health protective
> than the NESHAPS. Compliance rates have already been sent. Most of
> these facilities are small businesses and would face the same hurdles
> that dry cleaners would in navigating the administrative waters of
> Title V. Due to aggressive state and local rulemaking, permitting and
> enforcement, there would be no air quality benefit by requiring a
> Title V permit for these sources.
>
> I will call you today or tomorrow to see if you have any questions
> regarding SCAQMD\'s program or to see if you need more information to
> continue the deferral.
>
> Best regards,
>
> William C. Thompson
>
> Senior Manager
>
> Operations
>
> \(909\) 396-2398
>
> \-\-\-\--Original Message\-\-\-\--
>
> From: Vogel.Ray@epamail.epa.gov
> \[[mailto:Vogel.Ray@epamail.epa.gov]{.underline}\]
>
> Sent: Monday, July 21, 2003 5:37 AM
>
> To: William Thompson
>
> Cc: Swanson.Joanna@epamail.epa.gov; Hitte.Steve@epamail.epa.gov
>
> Subject: Re: FW: End of Area Source deferrals - Informal comments
>
> Thanks, William (can I call you Bill?) That information was very
> helpful.
>
> By way of followup, I\'m wondering if you might have any compliance
> rate information on the other categories (dry cleaners, degreasers, EO
> sterilizers, seconday lead and secondary aluminum). Also wondering if
> you have statistics about how many of these sources (including the
> chrome platers) get inspected and how often. If you\'d like, rather
> than you sending me this information in another email, I\'ll be glad
> to discuss this by phone.
>
> Ray Vogel
>
> Operating Permits Group, OAQPS
>
> 919-541-3153
>
> William Thompson
>
> \<WThompson@aqmd.g To: Ray Vogel/RTP/USEPA/US@EPA
>
> ov\> cc:
>
> Subject: FW: End of Area Source deferrals - Informal
>
> 07/18/03 12:13 PM comments
>
> Hi Mr. Vogel,
>
> I\'m forwarding this e-mail to you since Mr. Hitte is currently out of
> the office.
>
> Best regards,
>
> William C. Thompson
>
> Senior Manager
>
> Operations
>
> \-\-\-\--Original Message\-\-\-\--
>
> From: William Thompson
>
> Sent: Thursday, July 17, 2003 4:32 PM
>
> To: \'Hitte.Steve@epa.gov\'
>
> Cc: Mohsen Nazemi; Mike Mills; Jay Chen
>
> Subject: End of Area Source deferrals - Informal comments
>
> Dear Mr. Hitte,
>
> By way of introduction, I\'m the senior manager in charge of
> operations with the overall responsibility to track and coordinate the
> South Coast AQMD\'s Title V permitting program. I\'m also the AQMD\'s
> representative on the CAPCOA Title V subcommittee.
>
> The following are my informal comments to the proposal to end the
> deferral of area sources and dry cleaners from Title V permitting
> requirements.
>
> California has always been at the forefront of environmental
> regulations including those seeking to reduce toxic emissions.
>
> Currently, the state has adopted Air Toxics Control Measures (ATCM)
> for drycleaners, chrome platers, ETO sterilizers as well as for many
> other significant sources of toxics. By state law, South Coast AQMD
> (AQMD) must adopt these, or propose equivelant regulations, into our
> Regulation XIV. Some of these essentially mimic NESHAPS and some, like
> our Drycleaner rule which will eliminate perchloroethylene, are more
> emissions-reducing. The AQMD has a robust permitting and compliance
> system already in place that requires permits from major and non-major
> sources of HAPS.
>
> Compliance rates for these HAP sources are satisfactory. In a recent
> audit of chrome plating operations which included field inspections of
> 127 chrome plating facilities, the overall compliance rate (no
>
> violations) was over 82% with only 2% having direct emissions
> violations. The balance of the violations were administrative (\<12%)
> or emissions-related (\<4%).
>
> Since the AQMD already has a permitting system as well as a dedicated
> field enforcement division, it would be overly burdensome, without any
> air quality benefit, for these sources to apply for a Title V permit.
> Moreover, most of these sources are small businesses while others are
> \"mom and pop\" type organizations that couldn\'t navigate the rough
> administrative tangle the Title V permitting embodies.
>
> Therefore, since these sources are currently regulated through state
> and local programs, and it is far too burdensome to the sources, I
> believe that these area sources should continue to be deferred and
> consideration be given to a permanent exemption for California
> sources.
>
> If you have any questions, please call me at (909) 396-2398.
>
> William C. Thompson
>
> Senior Manager
>
> Operations