Ann Johnston, Vice Chair 

Mayor, City of Stockton 

Tony Barba 

Supervisor, Kings County 

DATE: June 16, 2011 

TO: SJVUAPCD Governing Board 

HEALTHY AIR LIVING' 

San Joaquin Valley 

AIR POLLUTION CONTROL DISTRICT 

GOVERNING BOARD 

J. Steven Worthley, Chair 

Supervisor, Tulare County 

1. 

Judith G. Case 

Supervisor, Fresno County 

Roan Dominici 

Supervisor, Madera County 

Henry Jay Forman, Ph.D. 

Appointed by Governor 

Randy Miller 

Mayor, City of Taft 

William O'Brien 

Supervisor, Stanislaus County 

Leroy Ornellas 

Supervisor, San Joaquin County 

Chris Vierra 

Mayor, City of Ceres 

Hub Walsh 

Supervisor, Merced County 

Raymond A. Watson 

Supervisor, Kern County 

Vacant 

Small City Representative, Kings County 

Vacant 

Large City Representative, Tulare County 

Vacant 

Appointed by Governor 

Seyed Sadredin 

Executive Director 

Air Pollution Control Officer 

Northern Region Office 

4800 Enterprise Way 

Modesto, CA 95356-8718 

1209) 557-6400•FAX 1209) 557-6475 

Central Region Office 

1990 East Gettysburg Avenue 

Fresno, CA 93726-0244 

1559) 230-6000•FAX 1559) 230-6061 

Southern Region Office 

34946 Flyover Court 

Bakersfield, CA 93308-9725 

1661) 392-5500•FAX 1661) 392-5585 

FROM: Seyed Sadredin, Executive Dire-ctor/APCO 

Project Coordinator: Errol Villegas 

ADOPT PROPOSED AMENDMENTS TO RULE 4605 

(AEROSPACE ASSEMBLY AND COMPONENT COATING 

OPERATIONS) 

RECOMMENDATION: 

Adopt Proposed Amendments to Rule 4605 (Aerospace 

Assembly and Component Coating Operations). 

2. Authorize the Chair to sign the attached Resolution. 

BACKGROUND: 

Rule 4605 (Aerospace Assembly and Component Coating Operations) 

was originally adopted December 1991 and was last amended in 

September 2007. This rule includes stringent emissions limitations 

that control VOC emissions from various aerospace coating 

operations. There are currently 14 facilities that are subject to the 

requirements of this rule with total aerospace coating emissions of 

only 0.02 tons per day of VOCs. 

On July 17, 2009, EPA evaluated Rule 4605 for meeting Reasonably 

Available Control Technology (RACT) requirements. EPA determined 

that Rule 4605 satisfied RACT requirements for aerospace assembly 

and component coating operations. However, EPA also determined 

that additional review was required to ensure RACT was satisfied 

based on an EPA Control Techniques Guideline (CTG) Document for 

this source category (EPA-4531R-97-004) that includes additional 

limitation for coatings that have limited applicability to Valley sources. 

EPA suggested consideration of additional requirements through a 

Technical Support Document (TSD). Today's recommendations will 

revise rule language in accordance with EPA's TSD and end the 18- 

month sanction clock associated with their action. 

RE: 

www.valleyairorg 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4605 (AEROSPACE ASSEMBLY AND COMPONENT 

COATING OPERATIONS) 

June 16, 2011 

DISCUSSION: 

On January 26, 2010, EPA published in the Federal Register a limited approval and 

limited disapproval Rule 4605. Because of the limited disapproval, sanctions will be 

imposed on the District unless EPA approves subsequent SIP revisions within 18 

months of the effective date of this action. The District is proposing to incorporate 

EPA's recommended changes, and stop the associated18-month sanction clock. 

Summary of Proposed Amendments to Rule 4605 

District staff is proposing 17 new coating categories to be added to Table 1 "VOC 

Content Limits" and lowering two existing VOC limits. Additionally, definitions will be 

added to Section 3.0 of the rule to clarify new coating types. To allow for rule 

dissemination, sell-through of stock, and ensure operator compliance, District staff 

proposes an effective date for the new and revised VOC content limits of January 1, 

2013. 

District staff is also proposing to include an exemption to some of the new VOC content 

limits for Department of Defense (DoD) classified coatings and aerospace vehicle 

coatings based on guidance provided in the CTG. Administrative changes to show 

updates to test methods and practices are also proposed to add rule clarity. 

Emission Reduction Analysis 

The ARB emissions inventory shows VOC emissions of 0.02 tons of VOC per day for 

this industry. VOC emissions reductions from the proposed amendments will be 

insignificant since most affected operators are already in compliance with the proposed 

amendments or can use readily available coatings compliant with the new categories. 

Cost Effectiveness Analysis 

Pursuant to California Health & Safety Code (CH&SC) §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. 

The proposed amendments to Rule 4605 would add federal RACT requirements but not 

BARCT or all feasible measures, and are therefore not subject to the cost effectiveness 

analysis mandate. 

Socioeconomic Analysis 

Pursuant to CH&SC §40728.5 (a) an assessment of the socioeconomic impacts is not 

required for any rule or regulation that only adopts a requirement that is substantially 

similar to, or is required by state or federal statute, regulation, or applicable formal 

guidance, such as a federal CTG. Since the proposed amendments to Rule 4605 

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SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4605 (AEROSPACE ASSEMBLY AND COMPONENT 

COATING OPERATIONS) 

June 16, 2011 

implement the CTG standards mandated by the federal Clean Air Act, a socioeconomic 

impact analysis is not required. The CTG limits are not expected to cause a significant 

socioeconomic impact as affected sources do not use coatings subject to the new 

categories, or can use readily available coatings compliant with the new categories. 

Rule Consistency Analysis 

As required by CH&SC §40727.2, District staff conducted a rule consistency analysis. 

That consistency analysis compared the elements of the 2007 version of Rule 4605 with 

the corresponding elements of other District rules, federal regulations and guidelines 

that apply to the same source category or type of equipment. Because this rule 

amendment project only incorporates changes suggested in EPA's TSD, much of the 

rule consistency analysis from the 2009 RACT SIP is still valid. Updates to the 2009 

RACT SIP Rule Consistency Analysis have been incorporated into the analysis which is 

included in the Draft Staff Report. Based on the updated analysis, District staff found 

that the proposed amendments to Rule 4605 would not conflict with federal rules, 

regulations, or policies covering similar stationary sources. 

Environmental Impacts 

Pursuant to the California Environmental Quality Act (CEQA), staff investigated the 

possible environmental impacts of the proposed amendments to Rule 4605. The District 

finds that the project is exempt per the general rule that CEQA applies only to projects 

which have the potential for causing a significant effect on the environment (CCR 

§15061(b)(3)). For these reasons, staff is proposing to file a Notice of Exemption upon 

Board adoption of the proposed amendments to Rule 4605. 

Rule Development Process 

As guidelines for amending Rule 4605 to incorporate the 19 VOC coating limits, District 

staff reviewed the CTG for this source category, the 2007 Ozone Plan, rules in other air 

districts, and Federal and State regulations. Staff also conducted literature and internet 

research when evaluating the 19 CTG limits for control of VOC emissions from coating 

operations at aerospace manufacturing and rework operations. Staff developed a 

survey for sources to inform the District as to the extent that these 19 new CTG limits 

would affect their business. Over two-thirds of the surveys were returned and most 

sources marked that they are currently using compliant coatings or that compliant 

coatings are available for them to use. District staff worked closely with those sources 

that indicated a potential impact as a result of the new limits. 

The notice of the public hearing for the proposed rule amendments was published in 

general circulation newspapers in each of the eight San Joaquin Valley counties, and 

will be made available for review on the District website. The public notice solicited 

written comments to be submitted, and identified the name and telephone numbers of 

the District staff who can answer questions and respond to comments. A summary of 

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SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4605 (AEROSPACE ASSEMBLY AND COMPONENT 

COATING OPERATIONS) 

June 16, 2011 

the comments received and District responses are presented in Appendix A of the Final 

Draft Staff Report. 

FISCAL IMPACTS: 

District staff expects no fiscal impact to the District to result from this action. 

Attachments: Attachment A: Resolution for Proposed Amendments to Rule 4605 — (5 pages) 

Attachment B: Proposed Rule 4605 - (20 pages) 

Attachment C: Final Draft Staff Report with Appendices for Proposed Rule 4605 — 

(106 pages) 

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