### Written Comments and Responses :

Rule 3.14: Surface Preparation and Clean

- up,

Rule 3.19: Vehicle and Automotive Coating Operations,

Rule 3.20: Wood Product Coatings Operations,

Rule 1.1: Definitions

ARB Comments received on April 18, 2011:

Rule 3.14

- Surface Preparation and Clean

- Up

1. Subsection (A.3.a) : We recommend reducing the threshold of 50 grams of VOC per liter

of material to 25 to grams of VOC per liter of material.

FRAQMD staff has reviewed the emission threshold . It was determi ned that the lower

em ission threshold recommended by CARB would p lace an unnecessary burden on

various businesses in the District . FRAQMD will k eep the proposed emissions threshold

because it provides a reasonable level of attainment without over

- regulatin g the

community

.

2. Subsection (A.4.a) : We recommend removing the exemption for low use. Removing the

exemption would provide consistency with other districts’ rules (e.g. Sacramento

Metropolitan AQMD and South Coast AQMD) and maximize the emission redu ction

benefits.

FRAQMD staff has reviewed the exemption threshold and believes it is necessary to

maintain the exemption for those small businesses who barely use any solvents over the

course of a year. Furthermore, FRAQMD’s exemption is similar to Distr icts such as Yolo

Solano AQMD and San Joaquin Valley APCD.

3. Subsection (C.1) : We recommend reducing the VOC content limits as indicated in the

following table:

Category VOC Content Limit

(grams/Liter)

Prior to

12/31/2011 Effective

12/31/2011

Product

Cleaning Coatings and Adhesives 50 25

Vehicles & Mobile Eqmt.

[Rule 3.19] Surface Prep 200 50 25

Handheld Spray 780 50 25

Wood Products [Rule 3.20] 200 50 25

Metal Parts and Products 50 25

Polyester Resins 50 25

Inks 50 25

Electrical Apparatus Components & Electronic

Components 100

Aerospace Components 200 g/L or 45

mm Hg VOC

Composite

Partial PressureMedical Devices, Pharmaceuticals, and

Pharmaceutical Products 800

Cleaning of

Application

Equipment Coatings and Adhesives 50 25

Vehicles & Mobile Eqmt. [Rule 3.19] 50 25

Wood Products [Rule 3.20] 50 25

Metal Parts and Products 50 25

Polyester Resins 50 25

Printing Operations: Screen, Lithographic, and

Letterpress, Ultraviolet, Flexographic, Gravure

(Publication) 100

Aerospace Components 50 25

Medical Devices, Pharmaceuticals, and

Pharmaceutical Products 810 800

Sterilization of food manufacturing and processing equipment 200

General: Industries Not Specified Above 50 25

See Comment #1. FRAQMD staff has accepted the change from 810 g/L VOC to 800 g/for

the Cleaning of Applica t ion Equipment for Medical Devices L.

4. Subsection (C.6) : We recommend reducing the 50 grams of VOC per liter of material to

25 to grams of VOC per liter.

See Comment #1.

5. Subsection (C.8) : We suggest reducing the 55 gallons of coatings and/or strippers per

year to 20 gallons.

The 55 gallon threshold is the current standard in District Rule 3.20. The District does not

feel it is necessary to reduce the thr eshold from 55 gallons to 20 gallons for the short

duration between Rule Adoption and December 31, 2011. The 55 gallon provision will be

obsolete after December 31, 2011. No changes were made.

6. Section (i) 2. a. 4 : Section (i) 2. a. 4 contains a possib le typo and should be revised to

read: "All purchase orders, invoices, and other documents to support information in the

monthly log."

The District does not understand this comment because the Section in reference does not

exist in Rule 3.14.

Rule 3.1 9

- Vehicle and Mobile Equipment Coating Operations

7. General : We recommend the district consider amending Rule 3.19 to incorporate the Air

Resources Board’s Suggested Control Measure (SCM) for Automotive Coatings.

Incorporating the SCM would make the rule consistent with rules in nearby districts such

as the Yolo

- Solano AQMD, and the proposed rule in Sacramento Metropolitan AQMD.

The District will evaluate the feasibility of implementing the SCM within the next few years.

### Public Workshop Comments received on April 21 , 2011 :

8

. When is the deadline to submit written comments for the Rule changes? [Beale AFB]

Tim Mitro, Air Quality Engineer for the District, noted that written com ments needed to

be submitted no later than May 23, 2011.



### EPA Comments received on May 1 3 , 2011:

Rule 3.14

- Surface Preparation and Clean

- Up

9. We concur CARB's April 18, 2011 recommendation to lower various VOC limits for various

solvent and cleaning products from 50 to 25 g/l to further reduce emissions and improve

consistency throughout the State.

See Comment #1.

10. Section 3 of the draft staff report supporting these rule revisions do not mention RACT as

part of the federal mandate. The staff report must demonstrate that these rules implement

RACT for any affected CTG or major non

- CTG sources within the federal Ozone

nonattainment area. We understand, based on the RACT SIP analysis adopted on

December 4, 2006, that the District does not believe there are CTG or major non

- CTG

sources affected by these rules.

A R ACT analysis was added to the staff report.

Rule 1.1

- Definitions

11. Feather River Rule 1.1 exempts TBAc from all treatment as a VOC. However, 40 CFR

51.100(s)(5) requires TBAc be treated as a VOC for purposes of recordkeeping, emissions

reporting, photoc hemical dispersion modeling and inventory requirements.

The District has noted this federal requirement.



### Beale AFB Comments received on May 20 , 2011:

Rule 3.14

- Surface Preparation and Clean

- Up

12. Beale AFB requests a military aerospace exemption be a dded to the proposed Rule 3.14,

Section A.3 Exemptions

– General . This will allow research to be conducted to find viable

low VOC solvents approved by the system program offices to be used on military

aerospace and fleet vehicles and equipment.

The District acknowledges Beale AFB’s requirements to meet military specifications. The

District has also identified that Santa Barbara APCD’s Rule 321 [amended 9/20/2010]

allows a 900 g/L VOC content for the cleaning of aerospace components and their supp ortprocessing equipment. SBAPCD’s staff report [July 30, 2010] noted that they allowed this

limit based on the comments from the regulated community and the Vandenberg Air Force

Base practice of using IPA.

Hence, the District will change the previously p roposed limits of 200 g/L or 45 mm Hg for

the product cleaning of aerospace components. The new proposed limits will be set to

SBAPCD’s limit of 900 g/L.

13. Beale AFB requests permits P9007 and P9009 be viewed as single facilities, allowing for

the “Low Use ” exemption under Section A.4 Exemptions

– Solvent Requirements

.

For those Air Districts which have placed a “Low Use” exemption into their rule, the typical

language applies to the net aggre gate amount of solvent used at a stationary source.

Beale AFB i s consid ered a single stationary source, as defined by District Rule 10.1

, Hence, the District will not view P9007 or P9009 as single facilities.



### ARB Comments received on June 1, 2011:

Rule 3.14

- Surface Preparation and Clean

- Up

14. Reiteration of Comments #1, 2, 3, 4, and 7.

All responses to these comments remain the same.