SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX A: Comments and Responses September 20, 2007

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- 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, 2007SAN JOAQUIN VALLEY UN IFIED 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 receiv ed.

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 p rinting 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: Th ese 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 t hat 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

oper ating 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 Operat ions (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 proces s 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 2 007 Ozone Plan evaluated the proposed changes and did not find significant reductions fromSAN JOAQUIN VALLEY UN IFIED 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 su bmitted 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 uniq ue 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 t o 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

allowan ce 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 d istrict'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 utiliz e 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 UN IFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX A: Comments and Responses September 20, 2007

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- 4 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

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