July 11, 2012

VIA E

- MAIL TO PATRICK AU

Mr. Michael Guzzetta, Manager

Rule Evaluation Section

Emissions Assessment Branch Stationary Source Division

Air Resources Board

P.O. Box 2815 Sacramento, CA 95812

Subject: Submittal of Recently Amended Rule s 102 (Definitions), 202 (Exemptions to Rule 201), 321

(Solvent Cleaning Machines and Solvent Cleaning)

, 330 (Surface Coating of Metal Parts and Products), 337 (Surface Coating of Aerospace Vehicles and Components), 349 (Polyester Resin Operations), and 35 3 (Adhesives and Sealants)

Dear Mr. Guzzetta:

On June 21, 2012 , the Santa Barbara County Air Pollution Control District Board of Directors held a Public He aring on adopting amendments to Rule 102 (Definitions), Rule 202 (Exemptions to Rule 201), Rule 32 1 (Solvent Cleaning Machines and Solvent Cleaning)

, Rule 330 (Surface Coating of Metal Parts and Products), Rule 337 (Surface Coating of Aerospace Vehicles and Components), Rule 349 (Polyester Resin Operations), and Rule 353 (Adhesives and Sealants) . Afte r the Public Hea ring, the Board adopted the amended rule s

. Transmit ted with this letter are the adopted amended r ule s for inclusion in to the California State Implementation Plan.

C hanges to the rules are summarized below:

 Rule 102, Definitions

The Di strict add ed:

 an enclosed cleaning system definition,

 an exempt compound definition,

 chemical names to the fluorinated gases definition,

 four USEPA

- identified exempt compounds to the reactive organic compound definition, and

 terms common to the other amended rules

.

 Rule 202, Exemptions to Rule 201

Replace d EPA Method 24 with South Coast AQMD Method 313

- 91 . Also mad e minor revisions (e.g., add rule and test method titles).

 Rule 321, Solvent Cleaning Machines and Solvent Cleaning

Revis e d the Section B.6 exemption to clarify that the exemption does not apply to solvent cleaning machines when an operation

- specific rule indicates such e quipment is subject to Rule 321 devices/methods to be used when performing solvent cleaning. Please note the substantive parts of Rule 321 were not amended and that EPA approved Rule 321 into the State Implementation Plan on September 29, 2011 (76 FR 60376).Page 2

 Rule 330, Surface Coating of Metal Parts and Products

Add ed Rule 321

- type exemptions, definitions, and general solvent cleaning, recordkeeping, reporting, source testing, and compliance provisions.

 Rule 337, Surface Coating of Aerospace Vehicles and Components

In addition to the changes outlined for Rule 330, the District add ed :

1. Adhesive and sealant provisions; and

2. Coating categories and limits from a USEPA Control Techniques Guideline (CTG) document and a federal regulation for the source ca tegory

. The District is also lowering the stripper ROC limit from 400 to 300 grams per liter in response to suggestions by the ARB and the USEPA.

 Rule 349, Polyester Resin Operations

The changes outlined f

or Rule 330 were included in proposed amended Rule 349. Lower polyester resin material monomer contents limits and a higher add

- on control equipment overall efficiency limit were also added. T hese new provisions have a 24

- month phase

- in period to allow for product sale

- through and available stock depletion. Lastly, staff made minor changes to the rule’s Attachment A, “Static Method for Determination of Volatile Emissions from Polyester and Vin yl Ester Resins.”

 Rule 353, Adhesives and Sealants

The District a mend ed the rule to include Rule 321

- type provisions like in the other rules. We a dd ed application equipment requirements and stripper use provisions. T he ROC

- content limit on several products were also re duced.

The following is provided to clarify our responses to the SIP Completeness Checklist and the associated material we are submitting:

1. Reference C hecklist Item 2 , Underline and Strikeout Copy of the Rule Attachment 4 to this letter provide s

prop osed amended Rules 102, 202 , 321 , 330, 337, 349, and 353 in strikeout and underline format without any omitted text. Underline strikeout formatted rules are also found in other attached documents:

a. This Letter’s Attachment 7 Board Letter, Attachment 4

. 1

b. This Letter’s Attachment 7 Board Letter, Attachment 5, Staff Report , which includes annotated

underline and strikeout formatted rules (Appendices A

- H ). 1

2. Reference Checklist Item 3 , Complete Copy of the Referenced Rules The SIP Completeness Checklist requests copies of all referenced rules, unless previously submitted as part of an earlier SIP submittal. Rules 102, 202, 321 , 330, 337, 349, and 353 reference R ules 102, 201, 202, 210, 317, 320, 321, 322, 323, 325, 326, 330, 331, 337, 339, 343, 344, 349, 351, 353, 354, 505, 802, 803, 804, and 806

. Our records

indicate that the District has previously submitted all of these rules as part of earlier SIP submittals.

Records also indicate that :

a ) the District withdrew Rule 210, Fees, from SIP c onsideration (letter dated June 26, 1997), and

b ) EPA indicated that Rule 210 need not be included in SIP submittals (email of June 24, 2008 from Andy Steckel to Patrick Au).

1 Proposed amended Rules 102, 202, and 321 found in the Board Letter (Att achment 4) and the Staff Report (Appendices A, B, and C) are not complete copies. Omitted text is denoted as “[. . .].”