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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 Corrections 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?  
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______________________________________________

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 workshop 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 missing language does not change the intent or requirements of the rule because 

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

language back to the Rule strengthens this section by enhancing 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 working 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 conditions 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. 

 
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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 text between section IV.C. and Table 2. This new 

section, based on the corresponding text from SJVUAPCD Rule 4684, should read: “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.” In addition, the reference in section III.B. to 

“Section IV.B.2, Table 1” should read: “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 exemption in Rule 432, section III is necessary. 

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

91. In addition to making that correction, we recommend 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 including the date of the last 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.