ATTACHMENT D

D

- 1 AIR POLLUTION CONTROL DISTRICT (DISTRI CT)

COUNTY OF SAN DIEGO

PROPOSED AMENDMENTS TO RULE 67.4

– METAL CONTAINER, METAL CLOSURE

, AND METAL COIL

COATING OPERATIONS



### WORKSHOP REPORT

A w orkshop notice was mailed to the companies and government agencies in San Diego County that may be subject to proposed amended Rule 67.4 Meta l Container, Metal Closure and M etal Coil Coating Operations. Notices were also mailed to all Economic Development Corporations and Chambers of Commerce in San Diego County, the U.S. Environmental Protection Agency (EPA), the California Air Resources Board (ARB), and other interested parties.

The workshop was held on January 13, 2011, and was attended by two persons

. Writ ten
comments were also received before and after t he works hop

. The workshop comments and District responses are as follows:

1. WORKSHOP COMMENT

Is it possible to use purchase records of cleaning materials instead of usage records to satisfy the rule record keeping requirements ?

DISTRICT RESPONSE

The purc hase records of volatile organic compound ( VOC )

- containing cleaning materials may be very helpful in de termining the total amount of VOC emissions from a facility. However, purchase records alone are not sufficient and could lead to an overestimate of emi ssions. U sage records are therefore required. For example, a facility may have a permit condition restricting the amount of daily emissions pursuant to New Source Review rules, such as 10 pounds of VOC

emission s per day. In order to calculate daily emis sions in this case , the actual usag e of VOC

containing materials is required.

For facilities that do not have permit conditions limiting the daily amount of VOC emissions, monthly usage record keeping should be sufficient and is permitted under Rule 67.4

. T he monthly usage of coatings or cleaning solvents can be determined , for example, by using dispensing r ecords, measuring the level of a material with a measuring stick, or weighing a

container with such materia l in the beginning and the end of each mont h.Workshop Report

Rule 67.4

D

- 2 2. WORKSHOP COMMENT

Is it allowable to keep monthly records of VOC containing materials instead of daily records?

DISTRICT RESPONSE

Yes

, monthly (or daily) record keeping is allowed pursuant to Subsection (f)(1)(ii) of the rule

, unless the facil ity uses emission control equipment and is therefore subject to the daily record keeping requirements of Subsection (f)(2)

. Furthermore

, as stated in the response to Comment 1,

in some cases daily records may be required as a permit condition, such as for compliance with any applicable New Source Review rules

.

3

. EPA COMMENT

It is recommended that Rule 67.4 include the ac tual approval date of EPA test methods

. If a test
method cited in the rule is developed by other agencies, such as other California a ir districts

, Section (g ) should specify the date this test method was approved by EPA.

DISTRICT RESPONSE

The District agrees. The proposed rule has been revised as suggested.

4

. EPA COMMENT

Subsection (g)(7) for the determination of capture efficie ncy of an emission collection system should be revised by adding the reference to 40 CFR 51, Appendix M, and Test Methods 204A through 204F

.

DISTRICT RESPONSE

Subsection (g)(7) has been revised as suggested.

5

. EPA COMMENT

Subsection (e)(1)(iii) spe cifies that overall control efficiency of add

- on air pollution control system must be at least 85%. Some o ther air districts in California require the overall control efficiency to be at least 90%. Rule 67.4 requ irements should be as stringent as similar rules in

other districts.Workshop Report

Rule 67.4

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- 3 DISTRICT RESPONSE

The District disagrees. It should be noted that there are only two comp a nies in San Diego County subject to Rule 67.4, with a combined total VOC emissions of less than four tons per

year. Therefore, an i ncremental emission reduction benefit of a control system with 90% overall

control efficiency versus 85% efficiency will be negligible. In addition, t o achieve a 90% overall control efficiency of a n air pollution control system, b oth the collection and em ission reducti on systems must be at least 95% efficient. Such requirements are very stringent and do not allow

for any minor deviations from the perfect functioning of both systems

, and this requirement

seem s to be excessive in this case.

6

. EPA COMMENT

S outh C oast A ir Q uality Management D istrict Rule 1125 requires coating application methods other than those specified in the rule to be at least as efficient as H igh V olume L ow P ressure (HVLP ) system . S ubs ection (d)(2)(vii) should be revised to stipulat e this.

DISTRICT RESPONSE

The District disagrees. Subsection (d)(2)(vii) already stipulate s that other coating application

methods may be used provided that their transfer efficiency is at least equal to one of the approved methods

, which include s HVLP

.

7

. EPA COMMENT

For clarity, all coating application methods listed in Subsection (d)(2) should be defined in Section (c).

DISTRICT RESPONSE

The definitions of various allowable coating application methods appear in a number of other

District coa ting rules. These definitions are identical from rule to rule. In order to keep source

specific rules as concise as possible, the District plans to include these definitions in the next revision of Rule 2 (Definitions), which contains the definition of t erms used throughout the District rules and regulations.

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02/02 /11