SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 16, 2010

A-1 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 

## APPENDIX A

Summary of Significant Comments And District Responses

September 16, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 16, 2010

A-2 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 16, 2010

A-3 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 

### Summary of Significant Comments and District Respon ses for

Proposed Amendments to Rule 4653

US EPA REGION IX STAFF COMMENTS

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

compliant adhesives and sealants from Section 6.1.1 because Rule 4653 does not limit the volume of compliant adhesives an d sealants. Rule 4653 should continue to require regular recordkeeping of all adhesive and sealant used because regular recordkeeping is recom mended by relevant federal guidance (e.g., Little Bluebook, page 11; a nd Model VOC Rules for RACT, page 21), State guidance (CARB Determination of RACT/BARCT for Adhesives and Sealants) and it is included in s imilar rules in other air districts. Removal of this requirement from a coat ing rule significantly shifts long-standing precedent. Regular recordkeep ing is needed to ensure compliance with VOC emission limits in permi ts, 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 complian ce with requirements to record noncompliant coatings. EPA is not aware t hat industry has demonstrated, or even indicated, that this recordke eping 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or outdated definitions and provisions which are no t needed to insure the clarity, comprehension or enforceability of the cur rent rule.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 re commended by federal guidance, to demonstrate compliance with ap plicable rule requirements. For example, operators claiming a lo w-use exemption in Section 4.0 are required to maintain usage records to demonstrate they are eligible for that exemption. Other operat ors must maintain

records of the VOC content of their adhesives and s olvents to demonstrate compliance with the Section 5.0 require ments.

• If emission usage records are necessary to ensure enforcement of other District rule requirements, such the BACT an d offset requirements under Rule 2201 (New and Modified Stat ionary Source Review Rule), recordkeeping can be required under t he authority of
those rules. As noted in EPA’s comment letter, the District can also obtain usage information for compiling emissions in ventory under the authority of District Rule 1160 (Emission Statement s).SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 16, 2010

A-4 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 Given the current economic climate, especially as i t applies to small Valley businesses, reducing unnecessary administrative bur den, 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 tim e.

STAKEHOLDER COMMENTS

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