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 August 30, 2010

Adoption Hearing: September 20, 2010

Agenda 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. Dressler, Air Pollution Control Officer

CONTACT: Douglas Grapple, 961-8883 (grappled@sbcapcd.org)

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

Solvent 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 which follows this Board Letter. 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: Adopt the associated rule findings (Attachment 2) in support of the 

proposed amended rules pursuant to Health and Safety Code Section 40727 regarding 

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

findings also acknowledge 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 

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

equipment requirements for solvent cleaning machines (degreasers), and sanctioned solvent 
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cleaning devices and methods. The District expects the proposed amended Rule 321 to result in 

about 0.5 tons per day of ROC emission reduction 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 amended Rule 321 provisions. The enclosed Staff 

Report (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 adopt Rule 321 

amendments. Once adopted, the District will submit all three 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-SL-2) in 

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

solvent cleaning machines, limit 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 content 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 scope 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 monitoring costs.

5. Reducing solvent costs for some sources due to the use of lower-ROC content solvents. 

Emission Reductions and Cost-Effectiveness:

The 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, the cost-effectiveness 

figures range from - $990 per ton (savings) to $2,167 per ton. And the range for solvent cleaning 

machine cost-effectiveness is -$3,310 (savings) to $12,940 per ton. 
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Implications to the District Workload 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 should 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 on 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 environmental documents, including the 2004 Clean 

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

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