SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Re sponses 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 4692SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Re sponses October 8, 2009

A-2 Final Staff Report With Appendices 

### APPENDIX A

Summary of Significant Commen ts 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 pr eviously used in Rule 4692 costeffectiveness calculations. Although Ba y 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, t he 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 charbr oilers, we recommend, as the District has stated in the Rule 4692 staff report, continued investigation of the costs and monitoring of success achieved in t he 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 re commend this section be modified as follows: “...For purposes of determining control efficiency, all particul ate 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 clar ification 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 me thods listed in Section 6.5 is used to
test for “the other cr iteria pollutants”.

Section 5.1.1: For clarif ication we recommend changing the referenced section
to Section 6.5.

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

Appendix A: Significant Comments and District Re sponses October 8, 2009

A-3 Final Staff Report With Appendices Section 6.5.1: The South Coast AQMD w eb 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 ci ted version of the method is not available which makes the testing impo ssible. 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 AQM D’s latest version, or make the cited
version of the test method availabl e 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 th is language is already part of the rule. In Sect ion 6.2.2, the operator is required to show records required in 6.2.1 to t he inspector upon request.

STAKEHOLDER COMMENTS FROM THE SEPTEMBER 17, 2009 GOVERNING
BOARD MEETING

No significant comments were received.

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

Appendix A: Significant Comments and District Re sponses October 8, 2009

A-4 Final Staff Report With Appendices This page intentionally blank.

For Revised Proposed Amendments to Rules 4692