SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses September 16, 2010 

A-1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

APPENDIX A 

Summary of Significant Comments 

And District Responses 

September 16, 2010 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses September 16, 2010 

A-2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

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

Appendix A: Significant Comments and District Responses September 16, 2010 

A-3 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Summary of Significant Comments and District Responses for 

Proposed Amendments to Rule 4653 

US EPA REGION IX STAFF COMMENTS 

COMMENT: The District has removed the requirement to maintain daily records of 

compliant adhesives and sealants from Section 6.1.1 because Rule 4653 

does not limit the volume of compliant adhesives and sealants. Rule 4653 

should continue to require regular recordkeeping of all adhesive and 

sealant used because regular recordkeeping is recommended by relevant 

federal guidance (e.g., Little Bluebook, page 11; and Model VOC Rules for 

RACT, page 21), State guidance (CARB Determination of RACT/BARCT 

for Adhesives and Sealants) and it is included in similar rules in other air 

districts. Removal of this requirement from a coating rule significantly 

shifts long-standing precedent. Regular recordkeeping is needed to 

ensure compliance with VOC emission limits in permits, it supports District 

requirements for sources to report emissions (e.g., SJVAPCD Rule 1160). 

Regular recordkeeping for compliant coatings helps facilities develop 

recordkeeping routines that should improve compliance with requirements 

to record noncompliant coatings. EPA is not aware that industry has 

demonstrated, or even indicated, that this recordkeeping is a significant 

burden. 

RESPONSE: A part of the District’s rule amendment process is to remove unnecessary 

or outdated definitions and provisions which are not needed to insure the 

clarity, comprehension or enforceability of the current rule. Since the rule 

provisions do not limit the amount of coating used, there is no underlying 

basis to retain the current requirement to maintain daily usage records in 

Section 6.1.4.2. 

• The rule does require regular recordkeeping, as recommended by 

federal guidance, to demonstrate compliance with applicable rule 

requirements. For example, operators claiming a low-use exemption in 

Section 4.0 are required to maintain usage records to demonstrate 

they are eligible for that exemption. Other operators must maintain 

records of the VOC content of their adhesives and solvents to 

demonstrate compliance with the Section 5.0 requirements. 

• If emission usage records are necessary to ensure enforcement of 

other District rule requirements, such the BACT and offset 

requirements under Rule 2201 (New and Modified Stationary Source 

Review Rule), recordkeeping can be required under the authority of 

those rules. As noted in EPA’s comment letter, the District can also 

obtain usage information for compiling emissions inventory under the 

authority of District Rule 1160 (Emission Statements). 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses September 16, 2010 

A-4 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Given the current economic climate, especially as it applies to small Valley 

businesses, reducing unnecessary administrative burden, while still 

maintaining adequate safeguards for public health, is a primary mission of 

the District. 

ARB STAFF COMMENTS 

No comments have been received from ARB at this time. 

STAKEHOLDER COMMENTS 

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