October 19, 2010

VIA E-MAIL TO PATRICK AU

Mr. Michael Guzzetta, Manager Rule Evaluation Section Emissions Assessment Branch Stationary Source Division Air Resources Board P.O. Box 2815 Sacramento, CA 95812

Subject: Submittal of Recently Amended Rule 102 (Def initions), Rule 202 (Exemp tions to Rule 201), and Rule 321 (Solvent Cleaning M achines and Solvent Cleaning)

Dear Mr. Guzzetta:

On September 20, 2010, the Santa Barbara County Air Pollution Control District Board of Directors held a public hearing on adopting amendments to Rule 102 (Definitions ), Rule 202 (Exemptions to Rule 201), and Rule 321 (Solvent Cleaning Machines and Solvent Cleaning). After th e public hearing, the Board adopted the amended rules. Transmitted with this letter are the adopted amended rule s for inclusion in California State Implementation Plan.

Some of the changes to the rules are summarized below:

 Rule 102, Definitions

The District added and modified several solvent-related definitions that are used in various parts of the rulebook. The definition of reactive organic compound was updated to include most of the exempt compounds listed in 40 CFR 50.100(s).

 Rule 202, Exemptions to Rule 201

The amended rule now includes the Rule 210 title (“Fees ”). Revisions to Sections I and U are necessary for consistency with the amended Rule 321 provisions and for rule clarity. The Rule 202.D.10.l provision requires sources to obtain an Authority to Construct and a Perm it to Operate when using certain newly-designated exempt compounds in excess of 1 gallon per year per stationary source.

 Rule 321, Solvent Cleaning Ma chines and Solvent Cleaning

Changes to Rule 321 require more-rigorous emission co ntrol techniques for solven t cleaning machines and establishes solvent ROC content limits for solvent cleaning and cold solvent cleaners. Also, vapor cleaning machines using a solvent with an ROC content greater than 50 grams per liter shall require additional emission reducing devices. The solvent cleaning exemption wa s deleted and the rule requires specific cleaning devices/methods to be used when performing solvent cleaning. The amended rule allows the airless or air-tight solvent cleaning machines in lieu of other control techniques. Also, the revised rule changed the recordkeeping to be monthly (revised from being quarterly).Page 2 The following is provided to clarify our responses to the SIP Completeness Checklist and the associated material we are submitting:

1. Reference Checklist Item 2, Underline and Strikeout C opy of the Rule Attachment 4 to this letter provides proposed amended Rules 102, 202, and 321 in strikeout and underline format without any omitted text. Underline strikeout formatted rules are also found in other attached documents:

a. Attachment 7 to this Letter Board Letter, Attachment 4, Proposed Amended Rule 102, Definitions, Rule 202, Exemptions to Rule 201, and Rule 321, Solvent Cleaning Machines and Solvent Cleaning. b. Attachment 7 to this Letter Board Letter, Attachment 5, Staff Report, which includes annotated underline and strikeout formatted rules (Appendices C, D, and F). 1

2. Reference Checklist Item 3, Complete Copy of th e Referenced Rules The SIP Completeness Checklist requests copies of all referenced ru les, unless previously submitted as part of an earlier SIP submittal. Rules 102, 202, and 321 reference Rules 102, 201, 202, 210, 320, 321, 325, 326, 33 0, 331, 337, 339, 343, 344, 349, 351, 353, 354, 505, 802, 803, 804, and 806. Our records indicate that the District has previously submitted all of these rules as part of earlie r SIP submittals. Records also indicate that:

a) the District withdrew Rule 210, Fees, from SIP consideration (letter dated June 26, 1997), and b) EPA indicated that Rule 210 need not be included in SIP submittals (email of June 24, 2008 from Andy Steckel to Patrick Au).

Hence, we have not included any of the referenced rules in this submittal.

4. Reference Checklist Item 8, Non-EPA Test Methods Rules 102, 202, and 321 include references to nonEPA test methods. The SIP Completeness Checklist indicates we may need to submit such test methods with this package. Our analysis indicates that many of the test methods and/or procedures have likely been previously submitted to EPA. 2 At this juncture, in lieu of submitting the test methods, we are providing the following table, which identifies 1) where a rule refe rences a non-EPA test method, 2) the test method name/number, and 3) if applicable, where the test method is available on the Internet. 3

Item Rule No., Definition or Section Test Method Internet Website Where the Test Method is Available Other Information

1 102, Gasoline definition Test Method for the Determination of the Reid Vapor Pressure Equivalent Using an Automated Vapor Pressure Test Instrument http://ccr.oal.ca.gov/linkedslice/default.asp?SP=CCR1000&Action=Welcome This test method is found in the California Code of Regulations, Title 13, Division 3, Chapter 5, Article 4, section 2297. 2 102,MultipleChamber Incinerator definition Standard Test Method for Pyrometric Cone Equivalent (PCE) of Fireclay and High Alumina Refractory Materials, ASTM Method C-24. http://www.astm.org/Standa rds/C24.htm

3 102, Organic Solvents Standard Test Method for Distillation Range of Volatile Organic Liquids, ASTM D 1078-05 http://www.astm.org/Standa rds/D1078.htm

1 With the exception of Rule 321, the strikeout and under line formatted rules in the Board Letter (Attachment 4) and the Staff Report (Appendices C, D, and F) are not complete copies. Om itted text is denoted as “[. . .].”
2 The test methods are likely within other air district rules.
3 Staff will provide the test method(s) upon request.Page 3

Item Rule No. , Definitio n or Section Test Method Internet Website Where the Test Method is Available Other Information

4 202, Sec tion U.2.b Standard Test Method for

Distillation Range of Volatile Organic Liquids

, ASTM D

- 1078

- 05 http://www.astm.org/Standa rds/D1078.htm

5 321, Initial Boiling Point definition, and Section P.2 S tandard Test Method for

Distillation Range of Volatile Organic Liquids, ASTM D 1078

- 05 Same as above.

6 321, Section P.3 Environmental Protection

Agency method described in 40 CFR, §52.741(a)(4)(iii) http://www.access.gpo.gov/ nara/cfr/waisidx_10/40cfr5 2_10.html The reference to this test method is in the SIP

approved Rule 321 that was adopted on September 18, 1997. A reference to the capture efficiency determination method in §52.741 also appears in SIP

approved Rules 349 and 354. 7 321, Section P.4 Environmental Protection

Agency method described in 40 CFR, §52.741(a)(4)(iv) and 40 CFR, §52.741(a)(4)(vi) Same as above. The reference to the test method in §52.741(a)(4)(iv) is in the SIP

- approved Rule 321 that was adopted on September 18, 1997. 8 321, Section P.7 Standard Practices for

General Techniques of Infrared Quantitative Analysis, ASTM E 168

- 06 http://www.astm.org/S tanda rds/E168.htm

9 321, Section P.7 Standard Practices for

General Techniques of Ultraviolet

- Visible Quantitative Analysis, ASTM E 169

- 04 http://www.astm.org/Standa rds/E169.htm

10 321, Section P.7 Standard Practice for Packed

Column Gas Chromatography, ASTM E 260

- 96 (2006) http://www.astm.org/Standa rds/E260.htm

5

. Reference Checklist Item 6, Public Comments, and Checklist Item 11, Additional Materials The District
respon ded to L yondell Chemical Co. comments i n Attachment 3 of the Board Letter. 1 D ue to receiving l ater comments , we responded to ARB and EPA comments in an Addendum Memorandum dated September 20, 2010 . This Addendum Memorandum is included in Attachment 7 to this submittal (Additional Materials)

. The Staff Report w as included as Attachment 5 to the Board Letter , which w e are also provid ing as Attachment 7 to this submittal (Additional Materials)

.

1 The “Board Letter” is also known as the “ Board of Directors Agenda Packet from the September 20, 2010 Adoption Hearing .”