SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses November 21, 2010 

A-1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

APPENDIX A 

Summary of Significant Comments 

And District Responses 

November 21, 2010 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses November 21, 2010 

A-2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses November 21, 2010 

A-3 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

Summary of Significant Comments and District Responses for 

Proposed Amendments to Rule 4612 

US EPA REGION IX STAFF COMMENTS 

1. COMMENT: EPA reviewed the draft rule and concurs with comments provided 

by CARB in their letter addressed to the SJVUAPCD on 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 also 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 apply to any noncompliant solvent. 

Section 6.2: Labeling requirements should also apply to solvents and 

require the manufacturer and repackager of solvents to include, on all 

containers, the VOC content for solvents, as supplied, 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 sections because solvents have 

many uses, some of which have nothing to do with solvent cleaning activities or 

motor vehicle coating operations. Coatings, however, have limited applicability 

and are more easy to determine if they are non-compliant. 

District Rule 4612 (Motor Vehicle and Mobile Equipment 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 create a regulation and 

standards that would be uniform throughout California.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses November 21, 2010 

A-4 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

Staff researched motor vehicle coating rules in other air districts in California and 

was unable to find any air district with prohibition of possession requirements, 

prohibition of specification requirements, or labeling 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. Additionally, if the District were to adopt a 

labeling requirement for solvents used at these facilities then the manufacturers 

of the solvents would have to make one set of labels 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 available to the District, ARB, and 

EPA upon request. Required records include the material 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.