Proposed New Regulations: Air Pollution in Santa Barbara
The Santa Barbara County Air Pollution Control District is proposing to amend District rules to reduce air pollution caused by cleaning solvents. The provisions would include requirements for work practices, reactive organic compound (ROC) content limits, and solvent cleaning devices and methods.The Santa Barbara County Air Pollution Control District is seeking to amend rules concerning Surface Coating of Metal Parts and Products (Rules 330), Surface Coating of Aerospace Vehicles and Components (Rules 337), Polyester Resin operations (Rules 349), and Adhesives and Sealants (Rules 353).
The purpose is to add general solvent cleaning provisions similar to those found in Rule 321, Solvent Cleaning Machines and Solvent Cleaning, to each of these operation-specific rules, in order to reduce the amount of air pollution in Santa Barbara’s atmosphere. In addition, the proposed revisions would add rule exemptions and other requirements currently found in Rule 321 (including recordkeeping and source testing) as well as establish a compliance time frame.
The District is also proposing to expand the definition of solvent to include any liquid containing any ROC or toxic air contaminant, as the term is defined in Rule 321, in order to preclude operators from switching from non-toxic to toxic solvents to meet the solvent cleaning requirements. It has been proposed that the ROC-content limits, specified in Rule 349 for polyester resin materials and Rule 337 coatings, also be lowered.
The District held a public workshop on the project, met with stakeholders, and collected and reviewed the resulting feedback. A hearing on the proposed amendments has not yet been held, but the rules are scheduled to be considered for adoption by the air district board in 2012.
About the Author
Deborah Hunsicker, REA, is an STC Senior Analyst and regulatory specialist and directs STC’s regional office in northern Idaho. She has over 20 years experience in environmental consulting and regulatory compliance. She is a recognized expert in federal and state hazardous waste and hazardous materials regulatory issues, and has assisted various legal and industrial clients in the development of customized environmental auditing protocols, legal requirements analyses, ongoing regulatory tracking, and compliance programs, as well as the assessment of enforcement options. Currently, she coordinates several projects for key clients that involve tracking federal and state regulatory changes and preparing monthly summary reports of final and proposed regulatory changes that may impact operations. Ms. Hunsicker is STC’s lead author and project manager for STC's California Environmental Audit Guide and training guide series, covering both federal and California training requirements. She is also a contributing author to the Environmental Auditing: Federal Compliance Guide and Environmental State Differences Summaries and Checklists, covering both hazardous waste and solid waste issues.