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March 26,2013 

United States Environmental Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

Transmittal of EPA Rule Review Comments 

To: Paul Hensleigh, Yolo-Solano Air Quality Management District 

phensleigh@ysaqmd.org 

Mike Guzzetta, California Air Resources Board 

mguzzett@arb.ca.gov 

From: Andrew Steckel, Rulemaking Office Chief 

steckel.andrew@epa.gov 

Re: Rule 1.1 and 2.31 drafts dated 3-15-2013 

We are providing comments based on our preliminary review of the 3-15-2013 draft rules identified above. We have noted 

that several of our previous comments on these rules have been incorporated and appreciate your efforts. Unless 

otherwise indicated, paragraph numbers refer to the draft rule referenced above. Please direct any questions about our 

comments to me at (415) 947-4115 or to Adrianne Borgia at (415) 972-3576. 

Rule 1.1: 

Section 202 Consider using the definition of "Air Contaminanf in SCAQMD's rule 102 which is a broader definition that 

includes similar substances but states that the term is not limited to those substances. 

Section 211 Consider using the definition of "Combustion Contaminant" in SCAQMD's rule 102 which uses the term 

"particulate matter" (which is defined in this rule) in lieu of "air contaminant". 

Section 219.17 While we do not believe this would be a basis for EPA disapproval, we recommend that T-butyl acetate 

be exempt except for record keeping consistent with 40 CFR 51.100. 

Section 219.19 Please remove the compound, Trans1-chloro-3,3,3-trifluoroprop-1-ene (Solsticen.11233zd(E)) from this 

list of exemptions. Because of an adverse comment, EPA withdrew the direct final action that would have exempted this 

compound. 

Section 219.24.i Please correct the spelling of Ethylfluoride. 

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manufacture trans-dermal drug delivery product using less than 3 gallons per day of ethyl acetate averaged over a 30 

calendar day period." As we previously commented, please add a similar limit of 3 gallons or less to avoid allowing 

uncontrolled use of ethyl acetate. 

Section 219 While we do not believe this would be a basis for EPA disapproval, we recommend that T-butyl acetate be 

exempt except for recordkeeping consistent with 40 CFR 51.100. 

Section 221 We recommend adding a definition of "Formulation data" referenced in Section 602.4, using language similar 

to the definition in SCAQMD rule 1143. 

Section 240 "Pharmaceutical" should be revised to "Pharmaceutical Manufacturing Plant" since the definition 

paraphrases the definition of Pharmaceutical Manufacturing Plant in YSAQMD rule 2.35. For consistency, consider using 

the same definition language used in rule 2.35. 

Section 247 We recommend revising the definition of "Solvent" to mention its properties as a diluent, thinner, dissolver 

and viscosity reducer such as defined in YSAQMD rule 2.29. 

Section 301 Table 1 - SCAQMD Rule 1171 limits VOC for Lithographic & Letterpress and for Ultraviolet (except screen 

printing) to 100 grams /liter. Please consider lowering the limits for these two categories to 100 grams/liter. 

Section 301.2 Since the District has repealed Rule 2.24, Solvent Cleaning Operations, please add a requirement for "a 

permanent, conspicuous label which lists the appropriate operating requirements," (Rule 2.24.d.4) to section 301 .2. 

Sections 303.2 and 303.3 Please correct the typos from" 0 E" to" °F". 

Section 304.2 The definition in SCAQMD rule 1122 includes directing the solvent spray downwards. Consider adding 

similar language to this section. 

Section 304.12 Consider adding language similar to SCAQMD rule 1122 to require a vapor level switch as an open-top 

vapor degreaser control. It is not clear that the "manual reset vapor level thermostat" will provide this same type of 

control. 

Section 306.6 Revise the section numbering from 306.1 to 306.6 Section 307.1, 307.2, 501.3, 602.4, 606, 607 Apostrophe's seem to be incorrectly printing as "="in these sections. 

Section 602.3 Please refer to SCAMQD Method 304-91 (Determination of Volatile Organic Compounds in Various 

Materials) and, for consistency, remove the February 1996 date or add Apri11996 to the reference to SCAQMD Method 

304-91. 

Section 603 Correct SCAQMD Method 303 to 303-91 and include the title, Exempt Halogenated VOC in Liquids, for 

CARB Method 432. 

Section 604 and 605 Several of the symbols in the calculations seem to have dropped out. 

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