SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses September 1 7, 2000

A - 1 Final Staff Report with Appendices for

Proposed Amendments to Rule 4603 and Rule 4684 

# APPENDIX A

COMMENTS AND RESPONSES FOR PROPOSED AMENDMENTS TO

RULE 4603 AND RULE 4684

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

Appendix A: Comments and Responses September 1 7, 2000

A - 2 Final Staff Report with Appendices for

Proposed Amendments to Rule 4603 and Rule 4684 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses September 1 7, 2000

A - 3 Final Staff Report with Appendices for

Proposed Amendments to Rule 4603 and Rule 4684 SUMMARY OF SIGNIFICANT COMMENTS AND DISTRICT STAFF’ S RESPONSES ON AUGUST 20, 2009 VERSION OF PROPOSED RULE 4603 AN D RULE 4684

EPA Comments

District staff has not received a comment letter fr om EPA at this time.

ARB Comments on Rule 4603

1. Comment : ARB suggested lowering the following coatings’ l imits to meet the

same limits as the South Coast AQMD:

Coating Type VOC Limit (g VOC/liter) General One-Component 120 General Multi-Component 120 Electric Dissipating Coatings and Shock-Free Coatings 360

Response: As stated by District staff in the Final Draft Staf f Report, the sole purpose of these proposed Rule 4603 amendments is t o incorporate the RACT requirements established by EPA in the 2008 CTG. T he South Coast limits are beyond RACT and are not prescribed in the CTG. Di strict staff will review the SCAQM rule provisions for potential emissions reduc tions, in the context of future attainment plan control measure.

2. Comment: ARB recommended that Section 5.11 be modified so a s to require that the storage containers be airtight.

Response: District staff incorporated the work practices s tandards recommended in the CTG. The CTG requires the storage container s used for VOC-containing materials to be kept closed at all times except whe n depositing or removing these materials. The CTG does not require airtight conta iners.

3. Comment: The definition of ASTM (American Society of Testi ng and Materials) is

outdated. For clarification ARB recommended that t he definition of ASTM be changed to ASTM International as it is since 2001.

Response: The definition has been modified. Please refer to the proposed rule for changes.

4. Comment: In Section 6.5 it is not clear what CFR the Distric t is referencing. For clarification, ARB suggested that the District refe rence the exact CFR where EPA

identifies the ASTM test method versions that shoul d be used.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses September 1 7, 2000

A - 4 Final Staff Report with Appendices for

Proposed Amendments to Rule 4603 and Rule 4684 Response : The section has been deleted since the ASTM test methods already specified the revision year as indicated in the rul e. Please refer to the proposed rule for changes.

ARB Comments on Rule 4684

Comment : Rule 4684 does not meet the requirements of sta te Health and Safety Code which requires districts with serious air poll ution to require comply with the

BARCT and all feasible measures. Other air distric ts rules (including SCAQMD, Sacramento Metropolitan AQMD, Ventura County APCD, Mojave Desert AQMD) have more stringent requirements for low use operat ions, polyester resin monomer contents, and higher capture and control efficiency than Rule 4684. It is critical for that the District take this opportunity to amend th e rule to incorporate these more stringent requirements, maximizing the emissions re ductions from the rule and ensuring Rule 4684 conforms to state law.

Response: As stated by District staff in the Final Draft Staf f Report, the sole purpose of these proposed Rule 4684 amendments is t o incorporate the RACT requirements established by EPA in the 2008 CTG for fiberglass boat manufacturing materials. The District understands the requirements of state law that requires ozone nonattainment areas to implemen t BARCT and all feasible measures. During the development of the Ozone Plan , the District did not recommend this source category as a control measure because no significant VOC reductions could be achieved by lowering the existi ng monomer VOC limits and increasing the capture and control efficiency. To be conservative, District staff assumed that emissions would be reduced by 2% if ne w monomer contents limits were implemented (i.e., 2% of 0.02 ton VOC/day 2011 baseline inventory equals 0.0004 tons/day). Few facilities in the District u se VOC emission control devices to

meet current resin limits of the rule, so total VOC reduction from increasing the control effectiveness is expected to be small, on t he order of 1% of the baseline

emissions, thus the cost effectiveness of increasin g the control efficiency would need to be evaluated in light of what appears to be minimal reduction. District staff will review the other air districts’ rule pro visions for potential emissions reductions, and schedule rulemaking as part of the District’s 2010 mid-course

review of the Ozone Plan.