CONTROL OF VOC EMISSIONS FROM 

LARGE APPLIANCE AND METAL FURNITURE 

SURFACE COATING PROCESSES 

25 Pa. Code Chapter 129 

40 Pa.B. 420 (January 16, 2010) 

Environmental Quality Board Regulation #7-449 

(Independent Regulatory Review Commission #2813)

Comment/Response Document 
Control of VOC Emissions from 

Large Appliance and Metal Furniture Surface Coating Processes 

On January 16, 2010, the Environmental Quality Board (Board, EQB) published a notice of 

public hearings and comment period on a proposed rulemaking concerning amendments to 

25 Pa. Code Chapter 129 (relating to standards for sources) to regulate emissions of volatile 

organic compounds (VOC) from large appliance and metal furniture surface coating processes 

(40 Pa. B. 420). The public comment period closed on March 22, 2010. 

Three public hearings were held on the proposed rulemaking as follows: 

February 16, 2010 Department of Environmental Protection 

1 p.m. Southwest Regional Office 

 Waterfront Conference Rooms A and B 

 400 Waterfront Drive 

 Pittsburgh, PA 15222 

February 17, 2010 Department of Environmental Protection 

1 p.m. Rachel Carson State Office Building 

 Conference Room 105 

 400 Market Street 

 Harrisburg, PA 17105 

February 18, 2010 Department of Environmental Protection 

1 p.m. Southeast Regional Office 

 Delaware River Conference Room 

 2 East Main Street 

 Norristown, PA 19401 

No comments or testimony were received from the public during the public comment period. 

The Independent Regulatory Review Commission submitted comments, which are summarized 

in this document. No comments were received from the Senate or House Environmental 

Committees. If adopted as a final-form rulemaking, the final regulation will be submitted to the 

U.S. Environmental Protection Agency (EPA) as a revision to the State Implementation Plan 

(SIP). 

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Table of Commentators to the Environmental Quality Board

Control of VOC Emissions from Large Appliances and Metal Furniture 

Surface Coating Processes Rulemaking # 7-449

(IRRC # 2813)

ID Name/Address One Page 

Summary 

Submitted 

for 

Distribution 

to EQB 

Provided 

Testimony 

Requested 

Copy of 

Final 

Rulemaking 

after EQB 

Action 

1. Independent Regulatory Review Commission 

Recordkeeping - Clarity

1. Comment: Proposed subsection 129.52a(d) (relating to compliance monitoring procedures), 

which requires the owners and operators of the regulated surface coating processes to maintain 

certain records, is unclear as to the format in which these records must be maintained. This 

should be clarified in the final-form regulation. (1) 

Response: The Department respectfully disagrees. Requiring regulated facilities to maintain 

records is a standard requirement. This requirement is found in many Board-approved 

regulations, including § 129.52(g) (relating to surface coating processes), for instance. Neither 

the Department nor the regulated sources have had difficulty understanding or complying with 

this requirement. 

2. Comment: Proposed subsection 129.52a(e) (relating to recordkeeping and reporting 

requirements), which requires that the records required under subsection 129.52a(d) be submitted 

to the Department “upon request,” is unclear as to whether this request will be made orally or in 

writing. This should be clarified in the final-form regulation. (1) 

Response: The Department agrees and has revised the final-form rulemaking to specify that the 

records shall be submitted to the Department upon receipt of a written request.