William
Thompson
<
WThompson@
aqmd
.
gov>

07/
23/
2003
01:
47
PM
To:
Ray
Vogel/
RTP/
USEPA/
US@
EPA
cc:
Mohsen
Nazemi
<
MNazemi1@
aqmd.
gov>,
Jay
Chen
<
JChen@
aqmd.
gov>,
Edwin
Pupka
<
EPupka@
aqmd.
gov>,
Ben
Shaw
<
BShaw@
aqmd.
gov>
Subject:
RE:
FW:
End
of
Area
Sourc
deferrals
­
Informal
comments
Hi
Mr.
Vogel,

I've
checked
with
SCAQMD's
compliance
managers
and
have
the
following
information
to
add:

A)
Drycleaners
are
typically
inspected
about
every
18
months
and,
thanks
to
newer
technologies,
emissions
complianc
rates
are
about
90%.
Overall
compliance
rates
for
this
source
category
are
lower
(
about
60%)
due
to
record­
keeping
infractions.
Most
dry
cleaner
owners
have
communications
concerns
so
much
effort
is
expended
in
outreach
to
associations
and
trade
groups.
So
far,
this
has
met
with
modest
success.
This
is
also
a
major
concern
with
eliminating
the
Title
V
deferral
for
this
area
source.
The
added
complexity
of
a
Title
V
permit
would
certainly
overwhelm
a
high
proportion
of
these
owner/
operators
resulting
in
frustration
and
non­
compliance
without
a
corresponding
air
quality
ben
Also
please
note
that
the
SCAQMD
adopted
an
amendment
to
it's
rules
that
eliminate
the
use
of
perchloroethylene
in
t
coming
years.
This
rule
is
http://
www.
aqmd.
gov/
rules/
html/
r1421.
html
.

B)
Degreasers
using
HAPs
are
quickly
being
phased
out
in
favor
of
aqueous
cleaners.
There
are
only
a
few
left
in
the
areas
regulated
by
AQMD
and
these
will
likely
be
retired
soon.
Needless
to
say,
these
are
inspected
annually
and
compliance
rates
are
high
(>
80%).

C)
There
are
7
ETO
sterilizers
in
operation
commercially.
These
are
all
inspected,
at
a
minimum,
annually.
As
in
the
ca
of
degreasers
using
HAPs,
compliance
rates,
due
to
the
small
number
of
facilities
and
the
nature
of
these
sources,
approaches
100%.
These
sources
are
subject
to
SCAQMD
Rule
1405
http://
www.
aqmd.
gov/
rules/
html/
r1405.
html
D)
There
are
two
secondary
lead
facilities
in
our
area
­
both
have
Title
V
permits
already.

E)
There
are
a
handful
of
secondary
aluminum
facilities.
These
are
all
inspected
annually
and
compliance
rates
are
satisfactory.
Getting
an
accurate
source
test
can
be
problematic
however,
so
we
continue
to
make
these
facilities
a
priority.

F)
The
SCAQMD
regulates
about
190
chrome
plating
facilities
and
these
are
inspected
at
least
annually.
Many
are
inspected
more
frequently.
SCAQMD
rule
1469
http://
www.
aqmd.
gov/
rules/
html/
r1469.
html
applies
to
these
facilities.
This
rule
has
technology
and
risk­
based
requirements
that
result
in
a
rule,
that
SCAQMD
believes,
is
more
health
protective
than
the
NESHAPS.
Compliance
rates
have
already
been
sent.
Most
of
these
facilities
are
small
businesse
and
would
face
the
same
hurdles
that
dry
cleaners
would
in
navigating
the
administrative
waters
of
Title
V.
Due
to
aggressive
state
and
local
rulemaking,
permitting
and
enforcement,
there
would
be
no
air
quality
benefit
by
requiring
a
Title
V
permit
for
these
sources.

I
will
call
you
today
or
tomorrow
to
see
if
you
have
any
questions
regarding
SCAQMD's
program
or
to
see
if
you
need
more
information
to
continue
the
deferral.

Best
regards,

William
C.
Thompson
Senior
Manager
Operations
(
909)
396­
2398
­­­­­
Original
Message­­­­­

From:
Vogel.
Ray@
epamail.
epa.
gov
[
mailto:
Vogel.
Ray@
epamail.
epa.
gov]

Sent:
Monday,
July
21,
2003
5:
37
AM
To:
William
Thompson
Cc:
Swanson.
Joanna@
epamail.
epa.
gov;
Hitte.
Steve@
epamail.
epa.
gov
Subject:
Re:
FW:
End
of
Area
Source
deferrals
­
Informal
comments
Thanks,
William
(
can
I
call
you
Bill?)
That
information
was
very
helpful.

By
way
of
followup,
I'm
wondering
if
you
might
have
any
compliance
rate
information
on
the
other
categories
(
dry
cleaners,
degreasers,
EO
sterilizers,
seconday
lead
and
secondary
aluminum).
Also
wondering
if
you
have
statistics
about
how
many
of
these
sources
(
including
the
chrome
platers)
get
inspected
and
how
often.
If
you'd
like,
rather
than
you
sending
me
this
information
in
another
email,
I'll
be
glad
to
discuss
this
by
phone.

Ray
Vogel
Operating
Permits
Group,
OAQPS
919­
541­
3153
William
Thompson
<
WThompson@
aqmd.
g
To:
Ray
Vogel/
RTP/
USEPA/
US@
EPA
ov>
cc:

Subject:
FW:
End
of
Area
Source
deferrals
­
Informal
07/
18/
03
12:
13
PM
comments
Hi
Mr.
Vogel,

I'm
forwarding
this
e­
mail
to
you
since
Mr.
Hitte
is
currently
out
of
the
office.

Best
regards,

William
C.
Thompson
Senior
Manager
Operations
­­­­­
Original
Message­­­­­

From:
William
Thompson
Sent:
Thursday,
July
17,
2003
4:
32
PM
To:
'
Hitte.
Steve@
epa.
gov'

Cc:
Mohsen
Nazemi;
Mike
Mills;
Jay
Chen
Subject:
End
of
Area
Source
deferrals
­
Informal
comments
Dear
Mr.
Hitte,

By
way
of
introduction,
I'm
the
senior
manager
in
charge
of
operations
with
the
overall
responsibility
to
track
and
coordinate
the
South
Coast
AQMD's
Title
V
permitting
program.
I'm
also
the
AQMD's
representative
on
the
CAPCOA
Title
V
subcommittee.

The
following
are
my
informal
comments
to
the
proposal
to
end
the
deferral
of
area
sources
and
dry
cleaners
from
Title
permitting
requirements.

California
has
always
been
at
the
forefront
of
environmental
regulations
including
those
seeking
to
reduce
toxic
emissions.

Currently,
the
state
has
adopted
Air
Toxics
Control
Measures
(
ATCM)
for
drycleaners,
chrome
platers,
ETO
sterilizers
well
as
for
many
other
significant
sources
of
toxics.
By
state
law,
South
Coast
AQMD
(
AQMD)
must
adopt
these,
or
propose
equivelant
regulations,
into
our
Regulation
XIV.
Some
of
these
essentially
mimic
NESHAPS
and
some,
like
ou
Drycleaner
rule
which
will
eliminate
perchloroethylene,
are
more
emissions­
reducing.
The
AQMD
has
a
robust
permitti
and
compliance
system
already
in
place
that
requires
permits
from
major
and
non­
major
sources
of
HAPS.

Compliance
rates
for
these
HAP
sources
are
satisfactory.
In
a
recent
audit
of
chrome
plating
operations
which
include
field
inspections
of
127
chrome
plating
facilities,
the
overall
compliance
rate
(
no
violations)
was
over
82%
with
only
2%
having
direct
emissions
violations.
The
balance
of
the
violations
were
administrative
(<
12%)
or
emissions­
related
(<
4%).

Since
the
AQMD
already
has
a
permitting
system
as
well
as
a
dedicated
field
enforcement
division,
it
would
be
overly
burdensome,
without
any
air
quality
benefit,
for
these
sources
to
apply
for
a
Title
V
permit.
Moreover,
most
of
these
sources
are
small
businesses
while
others
are
"
mom
and
pop"
type
organizations
that
couldn't
navigate
the
rough
administrative
tangle
the
Title
V
permitting
embodies.

Therefore,
since
these
sources
are
currently
regulated
through
state
and
local
programs,
and
it
is
far
too
burdensome
t
the
sources,
I
believe
that
these
area
sources
should
continue
to
be
deferred
and
consideration
be
given
to
a
permane
exemption
for
California
sources.

If
you
have
any
questions,
please
call
me
at
(
909)
396­
2398.

William
C.
Thompson
Senior
Manager
Operations
