SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX A: Comments and Responses September 20, 2007

A-1 Final Staff Report with Appendices

for Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

APPENDIX A

COMMENTS AND RESPONSES

September 20, 2007
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX A: Comments and Responses September 20, 2007

A-2 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

SUMMARY OF SIGNIFICANT COMMENTS AND RESPONSES

FOR THE AUGUST 16, 2007 VERSION OF THE RULES

ENVIRONMENTAL PROTECTION AGENCY (EPA) REGION IX STAFF COMMENTS

No comments were received.

CALIFORNIA AIR RESOURCES BOARD (ARB) STAFF COMMENTS

We have no comment on the following rules: Rule 4603, Rule 4604, Rule 4605, Rule 

4606, Rule 4612, Rule 4653, Rule 4661, and Rule 4663.

1. COMMENT: Rule 4607 controls emissions from graphic arts printing operations. 

ARB staff had several suggestions to strengthen the rule including decreasing 

the exemption level, lowering the flexographic ink and webbing adhesive VOC 

content limits, and increasing emission control system efficiency.

RESPONSE: These comments have already been answered in previous staff 

reports dated April 9, 2007 and June 18, 2007. No change to rule language is 

proposed for this rule project. Rule 4607 (Graphic Arts) will be opened for 

coatings and control system changes as part of the District’s 8-hour ozone plan. 

It is anticipated that the rule will go to public hearing in the fourth quarter of 2008. 

2. COMMENT: In Rule 4662, we recommend revising the requirements for open 

top vapor degreasers and conveyorized degreasers that are not cold cleaners to 

include VOC limit specifications, similar to SCAQMD Rule 1122, Section (e), 

which requires using a solvent with a VOC content of no more than 25 g/l.

RESPONSE: District staff believes that the design requirements and the 

operating requirements for the degreasers is as stringent as using 25 g/l material. 

3. COMMENT: The Staff Report identifies the purpose of the District’s proposed 

amendments is to revise the solvent-cleaning requirements of Rule 4684 

Polyester Resin Operations (Rule). However, while this may be your staff’s 

intent, the proposed amendments affect the core requirements of the rule, which 

apply to polyester resins operations. Further, the staff of the Air Resources 

Board (ARB) has determined that the process and control requirements for 

polyester resin operations are less stringent than what should be required. 

RESPONSE: This rule project only addresses solvent cleaning only, as District 

staff has made clear throughout this rule project. The District's 2007 Ozone Plan 

evaluated the proposed changes and did not find significant reductions from 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX A: Comments and Responses September 20, 2007

A-3 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

those measures. No change to rule requirements with respect to operations 

other than solvent cleaning were made.

STAKEHOLDER COMMENTS

The following stakeholder submitted comments:

DuPont Performance Coatings (DPC)

Trim Masters, Inc. (TMI)

4. COMMENT: Solvents for cleaning are needed for specific purposes at the 

different stages in the refinish process. During the initial surface preparation, 

cleaning solvents are used to remove road tar and heavy dirt, then subsequently 

used during refinishing to prepare surfaces to receive subsequent coatings. The 

use of effective solvents for cleaning is essential. Good surface preparation is 

the foundation of a good finish. The District’s Rule 4602 acknowledges this 

criticality by exempting solvent cleaners used for the removal of road tar from the 

established limits, when the solvent is applied from a hand-held spray bottle 

(5.8.5). The rule further acknowledges the unique requirements for effective 

surface prep of plastics by allowing for a higher VOC limit when applied in a 

similar manner (5.8.6). The proposed amendments to Rule 4612 do not reflect 

consideration for these processes, yet end-users are still challenged to achieve 

effective cleaning on all substrates in preparation of surfaces to receive all 

coatings. The limits established in the proposal are reflective of those included in 

the SCAQMD Rule 1171; however they are not reflective of this same rule’s 

allowance for the use of aerosol cleaners in limited volume. We believe that the 

District should not implement the SCAQMD more restrictive VOC limit exclusive 

of that district's allowances. This remains unaddressed. (DPC)

RESPONSE: District staff agrees with commentor. Please see Revised 

Proposed Rule 4612 for changes.

5. COMMENT: Rule 4653 Section 5.2.7 and 5.2.8 will meet the needs of Trim 

Masters, allowing us to use specialty spray guns such as the Tornado brand, 

developed specifically for the spray of adhesives (and not for the spray of paint). 

Since the coating requirements (for example, clumpy texture instead of smooth) 

are different for adhesive applications than for paint applications, the modification 

to this rule will enable Trim Masters to utilize the latest technology available, 

minimizing both raw material use and particulate air emissions. We support the 

modification to Rule 4653. (TMI)

RESPONSE: Comment noted.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX A: Comments and Responses September 20, 2007

A-4 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

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