Attachment 7

Board of Directors Agenda Packet from the September 16 , 2010 Adoption Hearing

,

Staff Report for Agenda Items on September 16, 2010, Calendar

,

Board of Directors Agenda Packet from the September 20, 2010 Adoption Hearing

,

an Addendum Memorandum

, and

an Errata Memorandum

## SANTA BARBARA COUNTY

AIR POLLUTION CONTROL DISTRICT

RULE 321 BOARD PACKAGE

Board Package for

Proposed Rule Changes to

Rule 102. Definitions

Rule 202. Exemptions to Rule 201

Rule 321. Solvent Cleaning Machines and Solvent Cleaning

Printed Aug ust 30, 2010

Adoption Hearing: September 20, 2010Agenda Date: September 20 , 2010

Agenda Placement: Regular

Estimated Time: 10 min

Continued Item: Yes



# Board Agenda Item

TO: Air Pollution Control District Board

FROM: Terry E. D ressler , Air Pollution Control Officer

CONTACT: Doug las Grapple, 961

- 8883 (grappled@sbcapcd.org)

SUBJECT: Amendments to the Definition of “Reactive Organic Compound” and Rules on

S olvent Cleaning Machines and Solvent Cleaning, Definitions, and Permitting

Provisions

RECOMMENDATION:

That the Board:

A. Hold a public hearing to receive testimony on proposed amended Rules 102 (Definitions),

202 (Exemptions to Rule 201), and 321 ( Solvent Cleaning Machines and Solvent Cleaning).

B. Approve the Resolution wh ich follows this B oard L etter. Approval of the resolution will

result in the following actions:

1. CEQA Findings : Adopt the CEQA findings (Attachment 1) pursuant to the California

Environmental Quality Act (CEQA) and the CEQA guidelines.

2. Rule Findings : A dopt the associated rule findings (Attachment 2) in support of the

proposed amended rule s pursuant to Health and Safety Code Section 40727 regarding

necessity, authority, clarity, consistency, nonduplication, and reference. The rule

findings also acknowle dge public comments on the proposed amended rules and adopt

the responses to public comments as findings of the Board (See Attachment 3).

3. Rule Adoption and Amendments : Adopt proposed amended rules (Attachment 4).

EXECUTIVE SUMMARY :

The Santa Barbara County Air Pollution Control District ( District ) proposes modifications to Rule

321 to implement requirements for solvent cleaning machines and solvent cleaning. The proposed

amend ed Rule 321 contains solvent reactive organic compound (ROC) content limits, revised

equipment requirements for solvent cleaning machines (degreasers) , and sanctioned solvent2

cleaning devices and methods. The District expects the proposed amended Rule 321 to result in

about 0.5 tons per day of ROC emission r eduction in Santa Barbara County. This rulemaking effort

also includes modifications to Rule 102 (Definitions) and Rule 202 (Exemptions to Rule 201) to

provide rule clarity and for consistency with the amend ed Rule 321 provisions. The enclosed Staff

Repo rt (Attachment 5) provides more details on this rulemaking project.

DISCUSSION:

Objective :

To help attain and maintain state and federal ozone standards, the District needs to adop t Rule 321

amendments . Once adopted, the District will submit all thre e rules for inclusion into the State

Implementation Plan.

Background :

The District last modified Rule 321 in 1997 to address ARB

- and U.S. EPA

- identified rule

deficiencies. The current rulemaking effort is the implementation of control measure (R

- S L

- 2) in

the Clean Air Plan, which indicated the District would revise Rule 321 to modify requirements for

solvent cleaning machines, lim it solvent ROC contents, and require control techniques for solvent

cleaning (e.g., wipe cleaning).

Implications to the Regulated Community :

The impacts from the revised rule will depend on the type of parts, products, and equipment being

cleaned and the cleaning processes being used. In general, the revised Rule 321 will require the use

of solvents with an ROC conten t suitable for the level of cleanliness needed. The rule amendments

will cause impacts to the regulated community and District staff by:

1. Requiring a permit for a source that uses certain compounds in excess of one gallon per

year.

2. Expanding the sc ope of applicability of Rule 321 to include solvents that contain toxic air

contaminants.

3. Requiring the application and verification of control techniques to comply with the Rule 321

requirements.

4. Increasing existing or creating new operating and m onitoring costs.

5. Reducing solvent costs for some sources due to the use of lower

- ROC content solvents.

Emission Reductions and Cost

- Effectiveness :

T he total emission reduction from modifying Rule 321 is about 195 tons of ROC per year

(approximately 0.5 tons per day)

. For surface cleaning control techniques, t he cost

- effectiveness

figures range from

- $990 per ton (savings) to $2,167 per ton. And the ran ge for solvent cleaning

machine cost

- effectiveness is

- $3,31 0 (savings) to $12,940 per ton

.3

Im plications to the District Workl oad and Budget :

The District anticipates the current staffing levels will handle the new Permit to Operate

applications and modification applications required by the rule amendments . Also, the current

staffing levels shoul d be sufficient for any increase in inspections and industry outreach programs

.

Public Review :

The District held its first workshop on this rule revision in May 2003 and held further workshops in

August 2008 and June 2009. The District made documents o n this project available for public

review on May 14, 2009, April 19, 2010, and July 19, 2010. On July 14, 2010, the Community

Advisory Council voted to recommend that the Board adopt the proposed amended Rules 102, 202,

and 321. The District published a public notice of the Board hearing to adopt the proposed

amended Rules 321, 102, and 202 on August 1 , 2010.

California Environmental Quality Act (CEQA) :

Pursuant to Section 15168 (c) of the State California Environmental Quality Act (CEQA)

Guidelines, the proposed amended rules were examined in the light of the program EIR for the 1991

Air Quality Attainment Plan and subsequent environment al documents, including the 2004 Clean

Air Plan Supplemental EIR. The APCD determined that a CEQA Addendum to exist ing

environmental documents must be prepared. CEQA Findings to be adopted by the APCD Board are

provided in Attachment 1. Any subsequent changes to the project description will necessitate

additional environmental review under the CEQA.

Concurrences :

County Counsel has reviewed this Board Letter and its attachments and approves them as to form.

SPECIAL INSTRUCTIONS:

After adoption by the Board, please have the Board Chair sign the attached resolution and return a

copy of the resolution along with a copy of the minute order to Douglas Grapple of the Air

Pollution Control District.

Attachments

Resolution

Attachment 1

- CEQA Findings

Attachment 2

- Rule Findings

Attachment 3

- Public Comments and Responses to Public Comments

Attachment 4

- Proposed Amended Rule 102, Definitions, Rule 202, Exemptions to Rule

201, and Rule 321, Solvent Cleaning Machines and Solvent Cleaning

Attachment 5

- Staff Report