## 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

1

### Paper, Film and Foil Surface Coating Processes

On November 7, 2009, the Environmental Qu ality 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 mate rials 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 a nd 129.52 (relating to general; and surface coating processes). The proposal wo uld 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 th e 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 commen tator that made the comment. A list of the commentators, including name and affiliation (i f 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 Coat ing Processes Rulemak ing #7-448 (IRRC #2807)

ID Name/Address Submitted one page Summary
for distribu tion to EQB Provided Testimony Requested Copy
of Final Rulemaking following EQB
Action

1 Independent Regulatory Review Commission (IRRC) 333 Market Street, 14 th 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 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. 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 r ecords required under subsection 129.52b(d) be submitted to the Department “upon request,” is uncle ar 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.