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 (Definitions), Rule 202 (Exemptions to Rule 201), and 

Rule 321 (Solvent Cleaning Machines 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 the public hearing, the Board adopted the amended rules. 

Transmitted with this letter are the adopted amended rules 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 Permit to Operate when using certain newly-designated exempt 

compounds in excess of 1 gallon per year per stationary source. 

 Rule 321, Solvent Cleaning Machines and Solvent Cleaning 

Changes to Rule 321 require more-rigorous emission control techniques for solvent 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 was 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 Copy 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 the Referenced Rules The SIP Completeness Checklist 

requests copies of all referenced rules, 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, 330, 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 earlier 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 references 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/linkeds

lice/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 underline formatted rules in the Board Letter (Attachment 4) and 

the Staff Report (Appendices C, D, and F) are not complete copies. Omitted 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., 

Definition or 

Section

Test Method

Internet Website Where 

the Test Method is 

Available

Other Information

4 202, Section 

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

Standard 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 SIPapproved Rule 321 that was 

adopted on September 18, 

1997. A reference to the 

capture efficiency 

determination method in

§52.741 also appears in SIPapproved 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/Standa

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 

responded to Lyondell Chemical Co. comments in Attachment 3 of the Board Letter.1 Due to receiving 

later 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 was included as Attachment 5 to the Board Letter, which we are 

also providing 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.”