1 

### LEVIN, NANCY

From: Jeremiah Cravens <CravensJ@co.kern.ca.us>

Sent: Monday, May 04, 2015 11:13 AM

To: LEVIN, NANCY

Subject: RE: EKAPCD Rules

Attachments: RULE 432 Polyester Resin Operations Correct ions Clean 5-4-15.docx; RULE 432 Polyester

Resin Operations Corrections Strikeout_underline 5-4-15.docx

Follow Up Flag: Follow up

Flag Status: Flagged

See attached: latest Rule 432 update (Clean and Strikeout).

Thanks,

Jeremiah

>>> "LEVIN, NANCY" <Levin.Nancy @epa.gov> 05/04/2015 9:48 AM >>>

Yes. Thanks, Jeremiah.

______________________________________________ Nancy Levin Air Rules Office

415.972.3848 levin.nancy@epa.gov

US EPA Region 9, 75 Hawthorne St (AIR

‐ 4) San Francisco, CA 94105

From: Jeremiah Cravens [mailto:CravensJ@co.kern.ca.us]

Sent: Monday, May 04, 2015 7:46 AM

To: LEVIN, NANCY

Subject: RE: EKAPCD Rules

Hard copies of the corrected rule with an explanation will be sent to Rule Book subscribers. The electronic copy on the

website will be updated and a copy will be sent to ARB for their records including their post of EKAPCD rules on the ARB

website.

Is it ok to proceed?

-Jeremiah

>>> "LEVIN, NANCY" < Levin.Nancy@epa.gov > 05/01/2015 10:35 AM >>>

Hi Jeremiah,

If these post

‐ Board

‐ action revisions are lawful procedurally under State law, then I think we can go ahead and approve

the revised version.

Do you have some process to ensure that the public has access to the revised version and, conversely, that the old

version is removed from their rulebook, both in hard copy and on

‐ line?2 ______________________________________________ Nancy Levin Air Rules Office

415.972.3848 levin.nancy@epa.gov

US EPA Region 9, 75 Hawthorne St (AIR

‐ 4) San Francisco, CA 94105

From: Jeremiah Cravens [ mailto:CravensJ@co.kern.ca.us ]

Sent: Wednesday, April 29, 2015 5:49 PM

To: LEVIN, NANCY

Subject: RE: EKAPCD Rules

Response to comments.

Comment 1:

Section IV.D.1. was included in the previous draft of Rule 432 and appears to be unintentionally removed from the final

draft that was submitted to ARB to be forwarded to EPA. Language for Section IV.D.1. is in the Rule 432 final staff

report and was included in the proposed draft Rule that was presented at the public wo rkshop and submitted to ARB

and EPA for review prior to adoption.

The District believes the following language for Section IV.D.1 was left out of the final draft by mistake:



### D. Organic Solvent Cleaning Requirements

1. An operator shall not use organic solvents for cleaning operations that exceed the VOC content limits

specified in Table 2.

The District believes adding this missin g language does not change the intent or requirements of the rule because

Section IV.D.2 reiterates information from Section IV.D.1. an d offers an alternative to complying with IV.D.1. Adding the

language back to the Rule strengthens this section by e nhancing clarity. The District considers adding the missing

language back to the rule as an administrative change and does not require Board approval.

Comment 2:

Rule 432 is based on SJVAPCD's Rule 4684, Polyester Resin not SCAQMD Rule 1162. Rule 4684 has a similar exemption

for use of less than 20 gallons/month of polyester resin material. This exemption is intended to create a less

burdensome atmosphere for small operations wor king with specialty projects or prototypes.

Comment 3 & 4:

Rule 432 has been corrected per your suggestions. The District considers these to be administrative corrections because

they appear to be typos and the cond itions or intent of the Rule has not been compromised by the updates.

While reviewing the Rule I noticed that Section VI. Compliance Schedule was labeled Section V. I corrected this as well.

Again it is an administrative change and does not require Board approval.

I have attached a corrected clean copy of Rule 432 for your approval along with a strikeout underline copy so you can

easily see what has been corrected.

Feel free to contact me should you have any further questions.3 Thanks,

Jeremiah

>>> "LEVIN, NANCY" < Levin.Nancy@epa.gov > 04/27/2015 5:17 PM >>>

Thanks. Here’s recommendations for 432. #1 is what we were talking about.



### 1. Section IV is missing a section D.1 and related te xt between section IV.C. and Table 2. This new

section, based on the corresponding te xt from SJVUAPCD Rule 4684, shoul d read: “D. Organic Solvent

Cleaning Requirements ... 1. An operator shall not us e organic solvents for cleaning operations that

exceed the VOC content limits specified in Table 2.” In addition, the reference in section III.B. to

“Section IV.B.2, Table 1” should r ead: “Section IV.D, Table 2.”

2. SCAQMD Rule 1162 does not exempt facilities that use less than 20 gallons of polyester resin materials

per month. Please consider whether this exemp tion in Rule 432, section III is necessary.

3. Section V.B.1 refers to SCAQMD Method 309, Attachme nt A. The correct test method number is 309-

91. In addition to making that correction, we recomme nd including the date of the last revision, February

1993. We do not see an Attachment A associated with Method 309-91, so we recommend deleting

“Attachment A.”

4. Section V.B.3 refers to SCAQMD Test Method 312. The correct method number is 312-91. In addition

to making that correction, we recommend incl uding the date of the la st revision, April 1996.

______________________________________________ Nancy Levin Air Rules Office

415.972.3848 levin.nancy@epa.gov

US EPA Region 9, 75 Hawthorne St (AIR

‐ 4) San Francisco, CA 94105

From: Jeremiah Cravens [ mailto:CravensJ@co.kern.ca.us ]

Sent: Monday, April 27, 2015 4:51 PM

To: LEVIN, NANCY

Subject: EKAPCD Rules

See attached staff reports for EKAPCD rules 402 and 402.2.