SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses October 8, 2009 

 A-1 Final Staff Report With Appendices 

APPENDIX A 

SIGNIFICANT COMMENTS AND DISTRICT RESPONSES 

October 8, 2009 

For Revised Proposed Amendments to Rules 4692
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses October 8, 2009 

 A-2 Final Staff Report With Appendices 

APPENDIX A 

Summary of Significant Comments and District Responses for 

Revised Proposed Rule 4692 dated August 20, 2009 

US EPA REGION IX STAFF COMMENTS 

No comments were received. 

ARB STAFF COMMENTS 

1. COMMENT: The District has removed the requirements for under-fired 

charbroilers that were proposed in the version of the rule to have been amended 

on June 18, 2009. This action resulted from inputs from industry which identified 

higher costs of control equipment than previously used in Rule 4692 costeffectiveness calculations. Although Bay Area AQMD, in their Rule 6-2, 

Commercial Cooking Equipment, and South Coast AQMD in their proposed Rule 

1138, Control of Emissions from Restaurant Operations, determined that costeffective control measures were available in their districts, the cost of controls 

available for installation in restaurants in the San Joaquin Valley Unified APCD 

were higher. 

Because there may be some uncertainty in the actual costs of the equipment to 

control emissions from under-fired charbroilers, we recommend, as the District 

has stated in the Rule 4692 staff report, continued investigation of the costs and 

monitoring of success achieved in the BAAQMD and SCAQMD as their rules 

become effective. 

 

RESPONSE: District staff will monitor both Bay Area AQMD and South Coast 

AQMD implementation of controls for charbroilers. 

2. COMMENT: ARB staff recommends the following changes for clarity: 

Section 3.6: For clarification we recommend this section be modified as follows: 

“...For purposes of determining control efficiency, all particulate collected using 

the test method specified in Section 6.5 shall be considered PM-10.” There is no 

test method detail in Section 6.7. 

Section 4.2.1: For clarification we suggest adding a reference to South Coast 

AQMD Source Test Method 100.1 or ARB Test Method 100 or the appropriate 

USEPA Test Methods. None of the test methods listed in Section 6.5 is used to 

test for “the other criteria pollutants”. 

Section 5.1.1: For clarification we recommend changing the referenced section 

to Section 6.5. 

For Revised Proposed Amendments to Rules 4692
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses October 8, 2009 

 A-3 Final Staff Report With Appendices 

Section 6.5.1: The South Coast AQMD web site does not contain a reference to 

this method with this date. The version on the South Coast AQMD web site has a 

published date of January 24, 2006. The cited version of the method is not 

available which makes the testing impossible. The South Coast Rule 1138 does 

Not cite a version number or date. For clarification we suggest the District should 

confirm the latest version of the test method is acceptable to their Rule and 

change the citation to current version’s published date, or drop the date and 

accept whatever is the South Coast AQMD’s latest version, or make the cited 

version of the test method available on the San Joaquin Valley Unified APCD 

web site. 

RESPONSE: Comments have been incorporated into rule language. 

3. COMMENT: Section 6.2.1: For clarification we suggest adding a language to 

the Rule that All Sales Receipts and Purchase Orders for meat must be made 

available to the inspector upon request. 

RESPONSE: District staff believes that the he intent of this language is already 

part of the rule. In Section 6.2.2, the operator is required to show records 

required in 6.2.1 to the inspector upon request. 

STAKEHOLDER COMMENTS FROM THE SEPTEMBER 17, 2009 GOVERNING 

BOARD MEETING 

No significant comments were received. 

For Revised Proposed Amendments to Rules 4692
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses October 8, 2009 

 A-4 Final Staff Report With Appendices 

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For Revised Proposed Amendments to Rules 4692