CONTROL OF VOC EMISSIONS FROM 

PAPER, FILM AND FOIL SURFACE COATING 

PROCESSES 

25 Pa. Code Chapters 121 and 129 

39 Pa.B. 6460 (November 7, 2009) 

Environmental Quality Board Regulation #7-448 

(Independent Regulatory Review Commission #2807)

Comment/Response Document 

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Paper, Film and Foil Surface Coating Processes 

On November 7, 2009, the Environmental Quality Board (Board, EQB) published a 

Pennsylvania Bulletin notice of public hearings and written comment period on the proposed 

amendments to Chapters 121 and 129 (relating to general provisions; and standards for sources) 

for paper, film and foil surface coating processes (39 Pa.B. 6460). The proposed rulemaking 

would amend Chapter 129 to limit emissions of volatile organic compounds (VOCs) from the 

use and application of coatings and cleaning materials in paper, film and foil surface coating 

processes. The proposal would add § 129.52b (relating to control of VOC emissions from paper, 

film and foil surface coating processes), and amend §§ 129.51 and 129.52 (relating to general; 

and surface coating processes). The proposal would also amend § 121.1 (relating to definitions). 

The comment period opened on November 7, 2009, and closed on January 13, 2010. Three 

public hearings were held on the proposed rulemaking as follows: 

December 9, 2009 Department of Environmental Protection 

1:00 PM Southwest Region Office 

 Waterfront A & B Conference Room 

400 Waterfront Drive 

Pittsburgh, PA 15222-4745 

December 11, 2009 Department of Environmental Protection 

1:00 PM Rachel Carson State Office Building 

Conference Room 105 

400 Market Street 

Harrisburg, PA 17105 

December 14, 2009 Department of Environmental Protection 

1:00 PM Southeast Regional Office 

 Delaware Conference Room 

2 East Main Street 

Norristown, PA 19401 

 

This document summarizes the written comments received from the Independent Regulatory 

Review Commission (IRRC). No written comments were received during the public comment 

period and no testimony was received during the public hearings. The Board invited each 

commentator to prepare a one-page summary of the commentator’s comments. No one-page 

summaries were submitted to the Board for this rulemaking. Each comment is listed with the 

identifying commentator number for each commentator that made the comment. A list of the 

commentators, including name and affiliation (if any), can be found at the beginning of this 

document. The final-form rulemaking, if adopted as a 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 for the Environmental Quality Board

Paper, Film or Foil Surface Coating Processes Rulemaking #7-448

(IRRC #2807)

ID Name/Address 

Submitted one 

page Summary 

for distribution 

to EQB 

Provided 

Testimony 

Requested Copy 

of Final 

Rulemaking 

following EQB 

Action 

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Independent Regulatory Review 

Commission (IRRC) 

333 Market Street, 14th Floor 

Harrisburg, PA 17101

Section 129.52b. - Clarity.

1. Comment: Proposed subsection 129.52b(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. No changes have been made to the final-form rulemaking concerning format in 

response to this comment.

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

requirements), which requires that the records required under subsection 129.52b(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.