SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Rule Consistency Analysis September 17 , 2009

E-1 Final Staff Report with Appendices for Rule 4695 

## APPENDIX E

RULE CONSISTENCY ANALYSIS FOR RULE 4695

September 17, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Rule Consistency Analysis September 1 7, 2009

E-2 Final Staff Report with Appendices for Rule 4695 

### APPENDIX E Rule Consistency Analysis

I. REQUIREMENTS OF ANALYSIS

Pursuant to Section 40727.2 of the California Healt h and Safety Code, prior to adopting, amending, or repealing a rule or regulation, the Di strict is required to perform a written analysis that identifies and compares the air pollu tion control elements of the rule or regulation with corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the same source category. The elements th at were analyzed are emission standards, monitoring and testing, and recordkeepin g and reporting requirements.

II. RULE CONSISTENCY ANALYSIS

A. District Rules

Facilities could be subject to other District rules including:

 Rule 1040 (Enforcement)  Rule 1070 (Inspections)  Rule 1081 (Source Sampling)  Rule 1090 (Penalty)  Rule 1100 (Equipment Breakdown)  Rule 1140 (Applicability of Emission Limits)  Rule 2010 (Permits Required)  Rule 2020 (Exemptions)  Rule 2040 (Application)  Rule 2050 (Cancellation of Application)  Rule 2070 (Standards for Granting Application)  Rule 2080 (Conditional Approval)  Rule 2092 (Standards for Permits to Operate)  Rule 2201 (New and Modified Stationary Source Revi ew Rule)  Rule 3010 (Permit Fee)  Rule 3020 (Permit Fee Schedule)  Rule 3100 (California Environmental Quality Act Fe e)  Rule 3170 (Federally Mandated Ozone Nonattainment Fee)  Rule 4001 (New Source Performance Standards)  Rule 4002 (National Emission Standards for Hazardo us Air Pollutants)  Rule 4102 (Nuisance)  Rule 4694 ( Wine Fermentation and Storage Tanks)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Rule Consistency Analysis September 1 7, 2009

E-3 Final Staff Report with Appendices for Rule 4695 The above-listed rules are not in conflict with, no r are they inconsistent with the requirements of Proposed Rule 4695.

B. Federal EPA Rules and Regulations

1. Best Available Control Technology (BACT)

There is no EPA BACT for Brandy Aging and Wine Agin g.

2. Reasonably Available Control Technology (RACT)

There is no EPA RACT for Brandy Aging and Wine Agin g.

3. Lowest Achievable Emission Rate (LAER)

There is no EPA LAER for Brandy Aging and Wine Agin g.

4. New Source Performance Standards (NSPS)

There is no EPA NSPS for Brandy Aging and Wine Agin g.

5. National Emission Standards for Hazardous Air Po llutants (NESHAPs)

There is no EPA NESHAP for Brandy Aging and wine Ag ing.

6. Maximum Achievable Control Technology (MACT)

There is no EPA MACT for Brandy Aging and Wine Agin g.

7. Federal Control Techniques Guideline (CTG)

There is no EPA CTG for Brandy Aging and Wine Aging

.

8. Alternative Control Technology (ACT)

There is no EPA ACT for Brandy Aging and Wine Aging

.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Rule Consistency Analysis September 1 7, 2009

E-4 Final Staff Report with Appendices for Rule 4695 7. EPA Policy on Recordkeeping

The recordkeeping requirement in Rule 4311 is consi stent with EPA’s policy to keep and maintain records for at least five years.

III. CONCLUSION

Based on the above analysis, District staff conclud es that none of the proposed requirements of Proposed Rule 4695 would conflict w ith federal rules, regulations, or policies covering similar stationary sources.