SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses 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, 2009 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses September 17, 2009 

A-2 Final Staff Report with Appendices For 

Proposed Amendments to Rule 4602

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses 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 Stakeholders at this time. 

STAKEHOLDER COMMENTS RECEIVED ON THE DAY OF THE PUBLIC HEARING 

Stakeholder sending comments: 

Alliance of Automobile Manufacturers (AAM) 

1. COMMENT: Alliance members have an interest in the proposed rule for its 

potential impact on suppliers and on potential future operations that may be 

located in this jurisdiction. Alliance recommends that Rule 4602 be made fully 

consistent with the federal control techniques guidelines (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 the District regulates for all 

types of operators, such as solvent cleaning requirements, emission capture and 

control standards, and application standards. All additions to rule language have 

been taken from other District rules that would qualify as default rules. Any 

operator that chooses to operate an automobile assembly plant with coating 

operations in the Valley would be subject to not only Rule 4602, but the default 

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

which rules to follow, staff chose to add these default 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 proposed rule language would require 

an emission control system to achieve overall capture 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 DISTRICT

Appendix A: Significant Comments and District Responses 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 achieve the emission standard 

imposed under Section 5.1 are adequate. The Alliance recommends that the 

SJVAPCD delete Section 5.2 in its entirety. (AAM) 

 RESPONSE: The purpose of Section 5.2 is to offer operators an alternative 

method of compliance to rule standards. Language requires the emission control 

system to be equal to or more effective than that achieved with the VOC content 

limit in order to ensure that if the operator chooses 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 reference the revised EPA Auto 

Protocol for VOC to prevent any confusion with regard to the document that is 

referred to in Section 5.1 and ensure that facilities 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 Topcoat Protocol” as the method by 

which to determine compliance with the limits in Table 1. (AAM) 

 RESPONSE: The revised EPA auto protocol is referenced in Table 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 requirement that 

operators use only solvents with a VOC content of equal 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 cleaning solvents. (AAM) 

RESPONSE: Please see response to Comment 1. 

5. COMMENT: The draft rule contains language that would limit the types of 

permissible coating application methods to one of the listed methods or a method 

with at least 65 percent transfer efficiency, if the operator does not have an 

emission control system in place that meets the requirements 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.