UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Santa Barbara County Air Pollution Control District, 

Rule 321, 

Solvent Cleaning Machines and Solvent Cleaning

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

August 2013
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RULE IDENTIFICATION

Agency: Santa Barbara County Air Pollution Control District 

(SBCAPCD)

SIP-Approved Rule: Rule 321 – Solvent Cleaning Machines and Solvent 

Cleaning

Amended – September 20, 2010

Submitted – April 5, 2011

Approved – September 29, 2011 (76 FR 60376)

Subject of this TSD: Rule 321 – Solvent Cleaning Machines and Solvent 

Cleaning

Amended – June 21, 2012

Submitted – September 21, 2012

RULE SUMMARY - Rule 321 establishes operating requirements for solvent 

cleaning machines and for solvent cleaning, stipulates the emission control system 

limits and lists the acceptable test methods. The rule also includes an Operating 

and Maintenance Plan, and Recordkeeping and Reporting requirements, and 

establishes a compliance schedule. The changes incorporated by the June 21, 2012

amendment are minor and only incorporate a change to the rule title for Rule 337 

in Section B-6-d from “Surface Coating Aircraft or Aerospace Vehicle Parts and 

Products” to “Surface Coating Aerospace Vehicles Components” and the addition of 

the caveat: 

”Notwithstanding this exemption, the applicable Rule 321 requirements apply if a 

rule for any above process specifies a solvent cleaning machine shall comply with 

the applicable provisions of Rule 321.”

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule:
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1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency – Rule 321 was partially evaluated against EPA’s Control 

Technique Guidelines (CTGs) titled, “Control of Volatile Organic Emissions 

from Solvent Metal Cleaning” (EPA-450/2-77-022, November 1977) and 

“Control Techniques Guidelines for Industrial Cleaning Solvents” (EPA453/R-06-001 September 2006), CARB’s RACT/BARCT guidance titled, 

“Organic Solvent Cleaning and Degreasing Operations” (July 18, 1991), and 

other state and local rules for this category were used to help evaluate the 

RACT requirements of CAA §182(b)(2). 

3. SIP Relaxation - We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the 

Act (CAA §110(l)) or modify, in a nonattainment area, any SIP-approved 

control requirement in effect before November 15, 1990 (CAA §193).

RULE EVALUATION

1. Enforceability – SBCAPCD’s Rule 321 specifies clear, unambiguous 

terminology and ROC limits. Each type of solvent cleaning machine has been 

addressed in terms of drainage, usage with high and low volatility solvents, 

when heat is applied, required freeboard height, etc. While the Emission 

Control System Requirements (section N) does not specify equipment, it does 

clearly indicate the required parameters. The Compliance Schedule (section 

T) clearly indicates the dates for full compliance for the various features of 

the rule. The requirement for submitting an Operation and Maintenance Plan 
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(section Q) further strengthens this rule’s enforceability through procedures 

and recordkeeping. 

2. Stringency – SBCAPCD’s Rule 321 is consistent with the EPA CTG:

Industrial Cleaning Solvents and CARB’s Determination of Reasonably 

Available Control Technology (RACT) and Best Available Retrofit Control 

Technology (BARCT) Organic Solvent Cleaning and Degreasing Operations. 

However, it does not have as stringent ROC levels as analogous rules in 

other districts including South Coast AQMD rules 1122 and 1171 and San 

Joaquin Valley APCD rules 4661, 4662 and 4663. SBCAPCD is in 

attainment with the national ambient air quality standards (NAAQS) and, 

therefore, more stringent requirements are not required at this time under 

national requirements for RACT (CAA § 182(b) (2)) or RACM (CAA §

172(c) (1)). 

3. The changes to Rule 321 do not constitute a relaxation and they actually 

extend the applicability of Rule 321 to any other operation-specific rule that 

includes the use of a solvent cleaning machine. 

Therefore, we propose to determine that our approval of the submittal would comply 

with CAA § 110(l), because the changes made were administrative in nature and are 

not expected to have an adverse effect on emission reductions. CAA § 193 does not 

apply to this proposed action because SBAQMD is designated attainment for VOC’s.

RULE DEFICIENCIES – We have identified no deficiencies in submitted Rule 321

sufficient for EPA to propose less than full approval. 
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ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

1. Consider reducing the solvent ROC limit to 25 grams/liter in the following 

subsections: B-2, B-13, B-15, G-3, H-7, I-7, J-11, K-6, L-11, M-2 and M-3. 

This will maximize the emission reductions and provide consistency with other 

district rules such as those in South Coast AQMD and San Joaquin Valley 

APCD.

2. Consider reducing the solvent 900 grams/liter ROC limit in section B-8-d to 

100 grams/liter for electronic apparatus and 800 grams/liter for medical 

devices similar to that in South Coast AQMD’s rule 1171. Similarly, consider 

using South Coast AQMD’s rule 1171’s 600 grams/liter limit for disinfecting 

and decontaminating the surfaces described in section B-14.

3. The limit of 800 grams/liter ROC for solvent cleaning of crude oil machines 

and equipment is unusually high. Please consider a lower limit and include 

this item in the Table 1 of Section M.

4. Please consider reducing the other limits in Table 1 of Section M according to 

the CARB recommendations that are currently in the South Coast AQMD 

Rules 1171 and 1124, and San Joaquin Valley APCD Rule 4663:

Solvent and Cleaning Activity ROC Limit

From To

g/l (lb/gal) g/l (lb/gal)

(a)Product Cleaning During Manufacturing 

Processes and Surface Preparation for 

Coating Application:

(i) General 50 (0.42) 25 (0.21)

(ii) Electrical Apparatus Components

 & Electronic Components 900 (7.51) 100 (0.84)
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(iii) Medical Devices & Pharmaceuticals 900 (7.51) 800 (6.7)

(b) Repair Cleaning and Maintenance Cleaning:

(i) General 50 (0.42) 25 (0.21)

(ii) Electrical Apparatus Components

& Electronic Components 900 (7.51) 100 (0.84)

(iii) Medical Devices & Pharmaceuticals:

(I) Tools, Equipment, & Machinery 900 (7.51) 800 (6.7)

(II) General Work Surfaces 900 (7.51) 600 (5.0)

(c) Cleaning of Coatings Application Equipment 950 (7.51) 25 (0.21)

(d) Cleaning of the Following Items and 

 Equipment and their Components: 900 (7.51) 200 (1.68)

(i) Aerospace Vehicles;

(ii) Aerospace Vehicle Payloads and Satellites;

(iii) Aerospace Vehicle, Aerospace Vehicle Payload, and Satellite:

(I) Transport Equipment (e.g., railcars, trucks, trailers, forklifts, and 

 containers), and

(II) Support Processing Equipment (e.g., clean rooms, tools, payload fairing 

 fixtures, alignment jigs, fuel and oxidizer loading carts and associated 

 transfer lines).

5. For clarity, please change the phrase in subsection M-2 from “...grams per 

liter of material...” to “...grams of reactive organic compound per liter of 

material...” Also, subsection M-2-a would be more complete if the 

requirement to store wipes in containers was added. 

6. The following revisions to Section P should be incorporated to support the 

enforceability of this rule:

a. Subsection 5: Method 2G is in 40 CFR, Part 60, Appendix A-2.

b. Subsection 8: Method 18 is in 40 CFR, Part 60, Appendix A-6.

c. For consistency, add reference 40 CFR, Part 60, Appendix A-7, to 

Methods 25 and 25A indicated in subsection 8. 
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d. The EPA approved version of ASTM E169, referenced in subsection 7, 

is 1993. For consistency indicate as ASTM E169-93 (2004). 

7. In Section R, daily recording should be required for all non-compliant solvents 

used including those which satisfy the requirements of Section B-15. 

EPA ACTION - EPA staff recommends a full approval of Rule 321 pursuant to CAA 

§110(k) (4) and §301(a). 

ADDITIONAL REFERENCES –

1. SBCAPCD Rule 321 – Solvent Cleaning Machines and Solvent Cleaning

submitted April 5, 2011

2. SBCAPCD Rule 321 – Solvent Cleaning Machines and Solvent Cleaning

submitted September 21, 2012

3. “Control of Volatile Organic Emissions from Solvent Metal Cleaning,” EPA450/2-77-022, November 1977. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197711_voc_epa450_2-77-

022_solvent_metal_cleaning.pdf

4. Control Techniques Guidelines (CTG): Industrial Cleaning Solvents, EPA 

435/R-06-001, September, 2006.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

001_ind_cleaning_solvents.pdf

5. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf

6. California Air Resources Board (CARB) Determination of Reasonable 

Available Control Technology (RACT) and Best Available Retrofit Control 

Technology (BARCT) for Organic Solvent Cleaning and Degreasing 

Operations July 18, 1991.