SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis June 16, 2011 

 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 B - 1

APPENDIX B 

Rule Consistency Analysis 

June 16, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

B - 2

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

B - 3

I. REQUIREMENTS OF ANALYSIS 

Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting, 

amending, or repealing a rule or regulation, the District is required to perform a written 

analysis that identifies and compares the air pollution control elements of Draft Rule 

4605 with the corresponding elements of existing or proposed District and United States 

Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to 

the same source category. The rule elements that were analyzed are emission limits or 

control efficiency, operating parameters and work practices, monitoring and testing, and 

recordkeeping and reporting requirements. 

II. RESULTS OF ANALYSIS 

A. District Rules 

Facilities could be subject to other District rules including: 

 Rule 2201 New and Modified Stationary Source Review Rule 

 Rule 4002 National Emissions Standards for Hazardous Air Pollutants 

 Rule 4603 Surface Coating of Metal Parts and Products 

 Rule 4612 Motor Vehicle and Mobile Equipment Coating Operations 

 Rule 4653 Adhesives 

 Rule 4661 Organic Solvents 

 Rule 4663 Organic Solvent Cleaning, Storage, and Disposal 

The above-listed rules are not in conflict with, nor are they inconsistent with the 

requirements of Proposed Rule 4605. 

There is only one District rule that has solvent cleaning requirements that are not part of 

this rule project – Rule 4612 (Motor Vehicle and Mobile Equipment Coating OperationsPhase II). It should be noted that Rule 4612 superseded the requirements in Rule 4602 

(Motor Vehicle and Mobile Equipment Coating Operations) on and after January 1, 2009. 

Rule 4612 was amended October 21, 2010 and incorporated the provisions of solvent 

cleaning operations. The proposed amendments to Rule 4605 are consistent with the 

requirements in Rule 4612. 

 

B. United States Environmental Protection Agency Rules and Regulations 

1. EPA-Control Technique Guidelines (CTG) 

1. The CTG EPA-453/R-97-004 1997/12 applies to Surface Coating Operations at 

Aerospace Manufacturing and Rework Operations located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit greater than 

or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

B - 4

extreme ozone nonattainment areas. District Rule 4605 is more stringent than the CTG 

limits for 34 categories. The proposed amendments to Rule 4605 will make it as 

stringent as the CTG in the 19 remaining categories. As such, District staff concludes 

that District Rule 4605 is more stringent than the CTG. 

2. The CTG EPA-450/2-77-034 1977/12 applies to Surface Coating of Large 

Appliances operations located in marginal, moderate, serious or severe ozone 

nonattainment areas that have the potential to emit greater than or equal to 25 tons/year 

of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone 

nonattainment areas. 

Since this CTG applies to large appliance coating; therefore, it will not be compared to 

SJVAPCD Rule 4605 which covers aerospace coating. 

3. The CTG EPA-450/2-77-022 1977/11 applies to VOC Emissions from Solvent 

Metal Cleaning operations located in marginal, moderate, serious or severe ozone 

nonattainment areas that have the potential to emit greater than or equal to 25 tons/year 

of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone 

nonattainment areas. 

This CTG applies to the use of the following degreasing equipment: cold cleaners, open 

top vapor degreasers, and conveyorized degreasers. Identified in the CTG are design 

and work practice standards for cold cleaners, open top vapor degreasers, and 

conveyorized degreasers, for example: cover the solvent tank, have a facility for waste 

solvent and draining cleaned parts, permanent labels on operating parts, close 

degreaser when not in use, drain parts until dripping ceases, no excessive splashing if 

solvent is sprayed. The CTG also identifies add-on controls such as refrigeration 

chillers and carbon control. 

SJVACPD Rule 4605 identifies solvent VOC content limits or a control system with 

efficiencies of at least 90% capture and 95% control, and that would not allow more 

emissions than if compliant materials were utilized. The general solvent limit is 200 g/L; 

the coating stripper solvent limit is currently 300 g/L. 

Since the CTG does not identify control requirements any more stringent than 

SJVACPD Rule 4605, District staff considers Rule 4605 at least as stringent as the 

CTG. 

2. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for aerospace coating operations. 

3. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for aerospace coating operations. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

B - 5

4. National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) and Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

1. 40 CFR 63 Subpart GG (National Emission Standards for HAPs: Aerospace 

Manufacturing and Rework Facilities) 

The requirements in this subpart are not directly comparable to the District Rule 4605 

VOC limits. The NESHAP HAP emission limits which are expressed in terms of percent 

HAP, HAP emission concentration, and mass (kg) of HAP per mass (kg) of solids are 

not directly comparable to the coatings VOC limit which is expressed in terms of grams 

(or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as 

applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be 

HAPs; therefore, there is no direct correlation between the NESHAP limit versus District 

Rule 4605 

VOC limits. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

B - 6

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