SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 17, 2009

A-1 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 

## APPENDIX A

Summary of Significant Comments and Responses

For

Draft Rule 4602

September 17, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 17, 2009

A-2 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 17, 2009

A-3 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 

### Appendix A Summary of Significant Comments and Responses for Proposed Rule 4602

US EPA REGION IX STAFF COMMENTS

No written comments have been received from EPA at this time.

ARB STAFF COMMENTS

No written comments have been received from ARB at this time.

STAKEHOLDER COMMENTS

No written comments have been received from Stakeho lders at this time.

STAKEHOLDER COMMENTS RECEIVED ON THE DAY OF THE PUB LIC HEARING Stakeholder sending comments: Alliance of Automobile Manufacturers (AAM)

1. COMMENT: Alliance members have an interest in the proposed r ule for its potential impact on suppliers and on potential futu re operations that may be located in this jurisdiction. Alliance recommends that Rule 4602 be made fully consistent with the federal control techniques guid elines (CTG) for this category of coating operations. (AAM)

RESPONSE: Rule 4602 was modeled after the CTG promulgated by EPA. However, the CTG had regulatory holes in it that th e District regulates for all types of operators, such as solvent cleaning requir ements, emission capture and control standards, and application standards. All additions to rule language have been taken from other District rules that would qua lify as default rules. Any operator that chooses to operate an automobile asse mbly plant with coating operations in the Valley would be subject to not on ly Rule 4602, but the default

rules as well. Therefore, in an effort to eliminat e confusion for operators as to

which rules to follow, staff chose to add these def ault limits to this rule, and to make it as comprehensive as other prohibitory rules at the District.

2. COMMENT: Section 5.2 is unnecessary, the use of controls is an inherent part of meeting the emission standards contained in the auto CTG and incorporated in Section 5.1. In addition, the August 20 propose d rule language would require an emission control system to achieve overall captu re and control efficiency of 90 percent, instead of the 85 percent level specified by the June 17 draft.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses September 17, 2009

A-4 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 Furthermore, the draft rule would require emission control systems to also result in VOC emissions equal to or less than those which would result from compliance with the operational and content limits. This would bring into question whether the partial controls used to achie ve the emission standard imposed under Section 5.1 are adequate. The Allian ce recommends that the SJVAPCD delete Section 5.2 in its entirety. (AAM)

RESPONSE: The purpose of Section 5.2 is to offer operators a n alternative method of compliance to rule standards. Language r equires the emission control system to be equal to or more effective than that a chieved with the VOC content limit in order to ensure that if the operator choos es to use a capture control system, then the same emission reductions would be achieved as with compliance with VOC content limits.

3. COMMENT: The Alliance would also like to reiterate that the SJVAPCD should revise Rule 4602 to explicitly incorporate by refer ence the revised EPA Auto Protocol for VOC to prevent any confusion with rega rd to the document that is

referred to in Section 5.1 and ensure that faciliti es use the most up-to-date version of the Protocol when calculating compliance . As it is currently written, Section 5.1 refers to “the revised Automobile Topco at Protocol” as the method by which to determine compliance with the limits in Ta ble 1. (AAM)

RESPONSE: The revised EPA auto protocol is referenced in Tabl e 1 of Section 5.1 of current rule language. Please see rule for language for details.

4. COMMENT: The August 20 Draft Rule 4602 retains the requireme nt that operators use only solvents with a VOC content of e qual to or less than 25 g/l of VOC and imposes restrictions on cleaning activities . Such a requirement is not feasible for automotive assembly coating operations , which is the reason why the CTG recommends use of work practices to address cle aning solvents. (AAM)

RESPONSE: Please see response to Comment 1.

5. COMMENT: The draft rule contains language that would limit t he types of permissible coating application methods to one of t he listed methods or a method with at least 65 percent transfer efficiency, if th e operator does not have an emission control system in place that meets the req uirements of Section 5.2. The CTG does not have these limits, therefore they should be removed from rule language. (AAM)

RESPONSE: Please see response to comment 1.