## 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 DocumentControl of VOC Emissions from Large Appliance and Metal Furn iture Surface Coating Processes

On January 16, 2010, the Environmental Quality Board (Board, EQB) published a notice of public hearings and comm ent period on a proposed rulemaking concerning amendments to

25 Pa. Code Chapter 129 (relating to standards for s ources) to regulate emissions of volatile organic compounds (VOC) from large appliance a nd metal furniture surfa ce 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 we re received from the public du ring the public comment period. The Independent Regulatory Review Commissi on submitted comments, which are summarized

in this document. No comments were received from the Senate or House Environmental Committees. If adopted as a fina l-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).

23 

### Table of Commentators to the Environmental Quality Board Control of VOC Emissions from Larg e Appliances and Metal Furniture Surface Coating Processe s 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 Regulator y Review Commission

Recordkeeping - Clarity

1. Comment: Proposed subsection 129.52a(d) (relating to compliance monitoring procedures), which requires the owners and operators of the re gulated 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 faci lities to maintain records is a standard requirement. This requirement is found in many Board-approved regulations, including § 129.52(g) (re lating to surface coating processes), for instance. Neither the Department nor the regulated sources have had difficulty unde rstanding or complying with this requirement.

2. Comment: Proposed subsection 129.52a(e) (relati ng to recordkeeping and reporting requirements), which requires that the record s required under subsection 129.52a(d) be submitted to the Department “upon request,” is unclear as to whether this reque st will be made orally or in writing. This should be clarified in the final-form regulation. (1)

Response: The Department agrees and has revised th e final-form rulemaking to specify that the records shall be submitted to the Department upon receipt of a written request.