SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses November 21, 2010

A-1 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 

## APPENDIX A

Summary of Significant Comments And District Responses

November 21, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses November 21, 2010

A-2 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses November 21, 2010

A-3 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 

### Summary of Significant Comments and District Respon ses for

Proposed Amendments to Rule 4612

US EPA REGION IX STAFF COMMENTS

1. COMMENT: EPA reviewed the draft rule and concurs with commen ts provided by CARB in their letter addressed to the SJVUAPCD o n October 14, 2010 and

have not identified additional concerns.

RESPONSE: Please see responses to ARB Comment 1.

ARB STAFF COMMENTS

1. COMMENT: The three of the provisions for coatings should als o be applied solvents, specifically:

Section 5.4 : The prohibition of possession should also apply to any noncompliant solvent.

Section 5.6 : The prohibition of specification should also app ly to any noncompliant solvent.

Section 6.2 : Labeling requirements should also apply to solve nts and require the manufacturer and repackager of solvents to include, on all containers, the VOC content for solvents, as suppli ed, expressed in grams per liter.

RESPONSE: Staff believe would be inappropriate to require all solvents in a facility to comply with the requirements in these s ections because solvents have many uses, some of which have nothing to do with so lvent cleaning activities or motor vehicle coating operations. Coatings, howeve r, have limited applicability and are more easy to determine if they are non-comp liant.

District Rule 4612 (Motor Vehicle and Mobile Equipm ent Coating Operations) was adopted to mirror the requirements in the California Air Resources Board Suggested Control Measure (SCM) for this source category. The adoption of the SCM requirements was a combined effort
between the air districts, EPA, and the ARB to crea te a regulation and standards that would be uniform throughout Californ ia.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses November 21, 2010

A-4 Final Staff Report with Appendices For Proposed Amendments to Ru le 4612 Staff researched motor vehicle coating rules in oth er air districts in California and was unable to find any air district with prohibitio n of possession requirements, prohibition of specification requirements, or label ing requirements as requested by ARB’s comment letter. Therefore, adopting these requirements would make this rule no longer consistent with other the motor vehicle coating operations

rules in other air districts in California. Additi onally, if the District were to adopt a labeling requirement for solvents used at these fac ilities then the manufacturers

of the solvents would have to make one set of label s specific to the SJVAPCD

and one set for the rest of California.

Although this rule does not require all solvents to be labeled, Section 6.5 requires the operator to keep records for solvents used for solvent cleaning at the facility for a total of five years and make such records ava ilable to the District, ARB, and EPA upon request. Required records include the mat erial safety data sheets,

which would contain information on the VOC content of the solvent.

STAKEHOLDER COMMENTS

No comments have been received from stakeholders or the general public.