SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses September 17, 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, 2009 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses September 17, 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 DISTRICT 

Appendix A: Comments and Responses September 17, 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 AND RULE 4684 

EPA Comments 

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

ARB Comments on Rule 4603 

1. Comment: ARB suggested lowering the following coatings’ limits 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 Staff Report, the sole 

purpose of these proposed Rule 4603 amendments is to incorporate the RACT 

requirements established by EPA in the 2008 CTG. The South Coast limits are 

beyond RACT and are not prescribed in the CTG. District staff will review the 

SCAQM rule provisions for potential emissions reductions, in the context of future 

attainment plan control measure. 

2. Comment: ARB recommended that Section 5.11 be modified so as to require that 

the storage containers be airtight. 

Response: District staff incorporated the work practices standards recommended 

in the CTG. The CTG requires the storage containers used for VOC-containing 

materials to be kept closed at all times except when depositing or removing these 

materials. The CTG does not require airtight containers. 

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

outdated. For clarification ARB recommended that the 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 District is referencing. For 

clarification, ARB suggested that the District reference the exact CFR where EPA 

identifies the ASTM test method versions that should be used. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses September 17, 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 rule. Please refer to the proposed 

rule for changes. 

ARB Comments on Rule 4684 

 Comment : Rule 4684 does not meet the requirements of state Health and Safety 

Code which requires districts with serious air pollution to require comply with the 

BARCT and all feasible measures. Other air districts rules (including SCAQMD, 

Sacramento Metropolitan AQMD, Ventura County APCD, Mojave Desert AQMD) 

have more stringent requirements for low use operations, 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 the rule to incorporate these more 

stringent requirements, maximizing the emissions reductions from the rule and 

ensuring Rule 4684 conforms to state law. 

Response: As stated by District staff in the Final Draft Staff Report, the sole 

purpose of these proposed Rule 4684 amendments is to 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 implement 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 existing monomer VOC limits and 

increasing the capture and control efficiency. To be conservative, District staff 

assumed that emissions would be reduced by 2% if new 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 use 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 the order of 1% of the baseline 

emissions, thus the cost effectiveness of increasing 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 provisions for potential emissions 

reductions, and schedule rulemaking as part of the District’s 2010 mid-course 

review of the Ozone Plan.