First Name | Jim |
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Last Name | Meyer |
Email Address | jmeyer@aviation-repair.com |
Affiliation | |
Subject | Source Test Frequency |
Comment | The requirement to source test pollution control systems very two years is unnecessary and extremely costly. It is unnecessary because ongoing compliance with Rule 1469 requires ongoing monitoring of control system parameters such as pressure drops and slot velocities and documented maintenance practices. District enforcement of these rule elements assures there is not a need for source testing frequency greater than every ten years. CARB's requirement to test every two years is unreasonable. If there is data that supports the need for testing frequency less than 10 years, CARB should present it. Even the current SC AQMD requirement is too frequent. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2023-01-17 07:52:12 |
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