Mr. Paul Hensleigh 

Yolo-Solano Air Quality Management District 

147 Galilee Court, Suite 103 

Davis, California 95618 

April9, 2013 

RE: Comments on proposed rule exempting Dimethyl Carbonate (DMC) as a VOC in Yolo-Solano AQMD 

Dear Mr. Hensleigh 

Kowa American Corp. would like to submit these comments in support ofthe proposed rule to 

exempt the solvent Dimethyl Carbonate as a VOC in the Yolo-Solano Air Quality Management District. 

Kowa American fully agrees with the proposed VOC exemption rule as written and strongly urges that 

the rule be adopted as soon as possible. 

We feel DMC being VOC exempt will allow your local businesses a much greater degree of 

flexibility in meeting the more stringent VOC restrictions moving forward. We also think that with the 

increasingly strict VOC regulations that having additional VOC exempt solvents is a form of regulatory 

relief that your constituents will welcome. 

Kowa American is the original petitioner to the federal government requesting they exempt 

Dimethyl Carbonate as a VOC. The exemption request was submitted in July 2004 and approved in 

January 2009 after a number of years of intense scrutiny on not only its Ozone reducing values but on its 

environmental, toxicity and safety profiles. Dimethyl Carbonate (along with possibly methyl acetate) 

is unique in that it has perhaps the lowest MIR value of any liquid organic chemical, which means it will 

produce less ozone in the air than any other solvent. 

Kowa understands that your Air Management District also takes into account factors beyond a 

chemical's photo reactivity. Your air district and citizens also interested in a chemical's toxicity, worker 

safety, and environmental fate when evaluating exemption petitions. DMC's profile in these endpoints is 

highly favorable and represents an environmentally friendly compound. Environmental fate data show 

DMC to be readily biodegradable, have a low potential to bioaccumulate, and have low toxicity to fish, 

daphnia, or bacteria (Environmental modeling suggests that that the material may possibly be harmful 

to algae). An internet search on DMC reveals a large number of articles and patent references that 

describe t he substance as a green chemical with very favorable safety health, and environmental 
The Office of Environmental Health Hazard Assessment (OEHHA} in the California EPA has come 

out on December 8, 2009 with a toxicity report on Dimethyl Carbonate. Their cover page of this report 

indicates that "environmental exposure to DMC by the general public by inhalation at dose levels likely 

to be achieved, the (Environmental Health Hazard) concerns appear to be relatively minor." 

Workers generally respond favorably to working with DMC, since the compound is only a nonirritating or only slightly irritating chemical. A key concern is that DMC does not have an objectionable 

odor to workers or neighbors. Finding a VOC exempt solvent with an agreeable odor is difficult since a 

number of the exempt (or proposed VOC exempt) compounds have very pungent odors, which would be 

especially bothersome to neighbors of factories or shops using these VOC exempt solvents. 

DMC is flammable with a flash point of 63 "F (16 •q and has a similar toxicity profile as 

Methanol, one of DMC's primary metabolites in the body. For these reason DMC should be used in 

primarily in industrial, automotive, outdoor or shop settings. DMC has a much safer toxicity profile and 

much higher recommended PEL than p-Chlorobenzotrifluoride or PCBTF (PEL= 20 ppm) that is used 

extensively as a VOC exempt solvent in California and the rest ofthe USA. 

Even with DMC's flammable liquid flash point of 63"F, DMC still represents a safer alternative to 

two existing VOC exempt solvents widely used in the U.S., acetone and methyl acetate, both with 

flash points of 15" F. We believe customers would prefer and, therefore, adopt DMC immediately as a 

replacement for acetone and methyl acetate. Such a change would result in less flammable products 

and/or safer working environments. 

We think the exemption of Dimethyl Carbonate as a VOC by your Air Management District 

would be a step forward in air pollution control, especially allowing your constituents and businesses 

regulatory relief with the opportunity to use additional VOC exempt solvents in order to meet their air 

pollution obligations. 

Sincerely, 

Mark K. Smith 

Sales Manager 
Mr. Paul Hensleigh 

Yolo-Solano Air Quality Management District 

147 Galileo Court, Suite 103 

Davis, California 95618 

RE: Rule 1.1 Proposed Amendments; ACA Comments 

Dear Mr. Fiesler: 

The American Coatings Association (ACA)1 Architectural and Industrial Maintenance (AIM) VOC 

Committee support the proposed amendments to Rule 1.1, specifically the exemption of Dimethyl 

Carbonate (DMC) and Propylene Carbonate as Volatile Organic Compounds. 

The coatings industry is under constant pressure to reformulate products that have a lower VOC 

content. As a result, there is a critical and urgent need for safe, effective and affordable exempt 

solvents and coating formulators need all available tools to formulate both lower VOC and lower 

reactivity coatings. Dimethyl Carbonate and Propylene Carbonate are useful for coatings formulations 

since they: 

- have low ozone reactivity potentials 

- have favorable characteristics - including a relatively high flashpoint, unobjectionable odor, and a 

relatively moderate evaporation rate 

- have been exempted by nearly all states 

- are relatively inexpensive compared to other exempt compounds 

If these amendments are adopted, there may be an incentive for industry to use these negligibly 

reactive compounds in place of more highly reactive compounds that are regulated as VOCs. As such, 

ACA supports the proposed amendments to Rules 1.1. 

1 The American Coatings Association (ACA) is a voluntary, nonprofit trade association working to advance the needs of 

the paint and coatings industry and the professionals who work in it. The organization represents paint and coatings 

manufacturers, raw materials suppliers, distributors, and technical professionals. ACA serves as an advocate and ally for 

members on legislative, regulatory and judicial issues, a.'td provides forums for the advancement and promotion of the 

industry through educational and professional development services. 

1500 RHODE ISLAND AVENUE N.W. o WASHINGTON, DC 20005 o T 202.462.6272 o F 202.462.8549 o www.paint.org 
David Darling, P .E. Tim Serie, Esq. 

Senior Director, Environmental Affairs Counsel, Government Affairs 

* * Sent via email * * 

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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 

phensleig h@ysaqmd. org 

Mike Guzzetta, Caiifornia 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) 947-41 15 or to Adrianne Borgia at (415) 972-3576. 

Rule 1.1: 

Section 202 Consider using the definition of u Air Contaminant" 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 recordkeeping consistent with 40 CFR 51.100. 

Section 219.19 Please remove the compound, Trans1-chloro-3,3,3-trifluoroprop-1-ene (So!sticem 1233zd(E)) from this 

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

compound. 

Section 219.24.1 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 April 1996 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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