----- Forwarded by Andrew Steckel/R9/USEPA/US on 08/09/2011 03:44 PM

-----

From: "Samir Sheikh" <Samir.Sheikh @valleyair.org>

To: Andrew Steckel/R9/USEPA/US@EPA

Cc: "Errol Villegas" <errol.villegas@valleyair.org>, "Jessi Fierro" <Jessica.Fierro@valleyair.org>,

Adrianne Borgia/R9/USEPA/US@EPA

Date: 08/09/2011 03:28 PM

Subject: RE: Rule 4605

- Aerospace Assembly and Component Coating Operations



### Yes, in the absence of a specific specialty coating limitation in the rule for these

coatings, any facility that would want to start using these coatings would have to meet

the general , more stringent limitations in the rule. If an issue in the future, the District

could also consider further amendments to Rule 4605 to include additional coating

categories, as appropriate.

- Samir

Samir Sheikh

Director, Strategies and Incentives

San Joaquin Valley Air Pollution Control District

559

- 230

- 5800

www.valleyair.org

From: Steckel.Andrew@epamail.epa.gov [mailto:Steckel.Andrew@epamail.epa.gov]

Sent: Tuesday, August 09, 2011 3:18 PM

To: Samir Sheikh

Cc: Borgia.Adrianne@epamail.epa.gov; Anna Myers; Errol Villegas; Jessi Fierro

Subject: Re: Rule 4605

- Aerospace Assembly and Component Coating Operations

Samir

- Thanks for getting back to us on this. Did you also confirm that, absent limits for such specialty

coatings in Rule 4605, if any source did use these coatings within the Distri ct, they would be subject to

more stringent general catch

- all limits in the rule?

- Andy

From: "Samir Sheikh" < Samir.Sheikh@valleyair.org >

To: Andrew Steckel/R9/USEPA/US@EPA, Adrianne Borgia/R9/USEPA/US@EPA

Cc: "Errol Villegas" < errol.villegas@valleyair.org >, "Jessi Fierro" < Jessica.Fierro@vall eyair.org >, "Anna Myers"

< Anna.Myers@valleyair.org >

Date: 08/09/2011 03:14 PM

Subject

: Rule 4605

- Aerospace Assembly and Component Coating Operations

### Hello Andy and Adrianne,

We appreciate the opportunity to provide additional information to EPA about the San

Joaquin Valley Unified Air Pollution Control District (District) Rule 4605 (Aerospace

Assembly and Component Coating Operations), specifically regarding the following

thre e categories of coatings included in the EPA Control Techniques Guideline:

corrosive prevention compound, cryoprotective coating, and insulation covering coating.

District staff has contacted affected facilities subject to Rule 4605 to verify the use of

these coatings, and has confirmed that no facility uses the three coatings subject to the

CTG. It is important to note that the emission inventory for the source category of

Aerospace Assembly and Component Coating Operations is 0.02 tons per day (tpd ).

Given the overall low inventory and relative usage of individual specialty coatings,

amending rule language to include these three additional coatings or make limits for

existing coatings more stringent would have little to no impact on the District ’ s efforts to

achieve attainment of federal ozone standards.

Thank you for working closely with us in reviewing this rule and addressing your

concerns.

- Samir

Samir Sheikh

Director, Strategies and Incentives

559

- 230

- 5800

www.valleyair.org

samir.sheikh@valleyair.org