From: Bruce Springsteen

To: Molly Johnson
Subject: FW: Placer County APCD Rule 234

Date: Tuesday, October 19, 2010 2:25:37 PM

Attachments: Placer County Rule 234 comments.pdf

Bruce Springsteen Associate Engineer Placer County Air Pollution Control District 3091 County Center Drive, Suite 240

Auburn

, CA 95603 Direct: (530) 745-2337 Main Office: (530) 745-2330 Fax: (530) 745-2373

E-Mail: bsprings @placer.ca.gov

=======================================

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From: Koss, Mike [mailto:mkoss@ppg.com]

Sent: Friday, August 20, 2010 11:17 AM

To: Bruce Springsteen Subject: Placer County APCD Rule 234



### Mr. Springsteen,

I work for a refinish coatings manufacturer. I have heard you are interested in comments from the
public & manufacturers, impacted by this rule.

I have reviewed your draft version of Rule 234 and have a number of comments, by all means let
me know if you have any questions or comments in return.

Thanks for considering/reviewing.

Mike Koss

PPG Industries Mgr. Regulatory Affairs Refinish/ Fleet/ CPC

Phone: 216-671-7152

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# PPG INDUSTRIES

Automotive and Fle et Finishes 3800 West 143 rd Street, Cleveland, OH 44111

216 671

- 7152 Fax 216 671

- 7691

E

- Mail: mkoss@ppg.com

MIKE KOSS MANAGER, REGULATORY AFFAIRS AUTOMOTIVE,FLEET, & LIGHT INDUSTRIAL FINISHES

August 19 , 2010

Bruce Springsteen Associate Engineer Placer County Air Pollution Control District 3091 County Center Drive, Suite 240 Auburn, CA 95603 Direct: (530) 745

- 2337 Main Office: (530) 745

- 2330
Fax: (530) 745

- 2373

Subject: P roposed draft versio n of Placer County APCD Rule 234

M r

. Springsteen :

We appreciate the opportunity to comment on the new draft version of Placer County APCD

Rule 234 and a pologize for the late timin g of this dispatch

. We view this rule a s a complex topic

, impacting customer s, distributors and coatings manufacturers and would hope that you would consider our comments in your rule development process. We understand that the CARB SCM was used as a guideline/model rule and do not expect your district to vary significantly from t hat text. We know district to district

, modest rule variations are possible, allowing end users to more easily transition to the spirit of the rule.

With that understanding, we have the f o llowing comments /requests :

1.) Under Definitions 216 Exempt Compounds , we would ask that you consider allowing TBAc to be included as an exempt solvent , preferably all owed in all refinish products as in San Joaquin Valley Rule 4612 (3.42) or at least as S outh Coast Rule 1151 (c) (33) allows in Color C oatings and Clear Coati ngs . This solvent would be a valuable tool to formulate new products wi thout variable restrictions as seen in
California air districts today

. 2.) Under Definitions 227 Reducer , we would ask that the definition be expended from “enamel” to “coatings” as it is p ossible for reducers to be used to thin al l types of coatings (color, primers & clears...) & chemistries (enamel, urethane & latex...) 3.) Under 305 , we would ask that you consider sett ing applicator cleaner solvents a t a
maximum al lowed VOC content of 6.5 lbs/gal if used in an approved enclosed spray gun cleaning device per 305.3 . If designed properly

, this device would more effic iently

clean using less solvent, with minimal escap e of vapors. 4.) Under 305.4 we would ask that you consider allowing aerosol cleaners as listed in
South Coast AQMD Rule 1171 (h) (4). Aerosol package d cleaners al l ow an efficient application of cleaning solvents

- less waste, l ess emission s , less repeat appli cations

.page 2

5.) Also under 305.4 , solvent for substr a t e cleaner limits are set in “ VOC conte nt ” which I
believe is the same as VOC Actual content; however I do not see th e formu la set in

the definitions section 237 for “ VOC content ”

. 6.) Under 501.4 facility oper ators are required to maintain “P urchase records identifying coating type

, name and volum e of coating”. W e would ask that you consider revising
501.4 to requiring “P urchase records identifying coating type

, product name and

volume of coating (where product data sheets or manufacturer specification sheets would be an acceptable medium to mainta in coating type data)

. ” 7.) 501.1 (c) also asks for “ Material type , coating category and specific use instruct ions ”

. Again we ask that this line be changed to “ Material type , coating category and specific use instruct ions ( where product data sheets or manufact urer specification sheets would be an acceptable medium)” 8.) Similarly, u nder 503.2 “ Volume & type of material ” data is asked to be kept specifically in sales records by the distributor , we ask that 503.2 be changed to

“ Material name , v olume & type of mater ial (where product data sheets or manufacturer specification sheets would be an acceptable medium to maintain type of

material data)” 9.) With respect to 6, 7 & 8 we wo uld hope that “material type” “coating type”, “type of material”, “coating category” & “A pplicable Use C ategory ” listings are interchangeable

and would be accepted in product data she ets or m anufacturer specification sheets
and of course on container labels and it would not be necessary to revise multiple reporting formats to accommodate a req uest that is already satisfied multiple times. We might suggest if int ended to b e the same meaning that o ne term be consistently used, “Applicable Use C ategory” is commonly used in the districts

. 10.) References to “ Metallic C oatings ” in 220 & 507.6 seem t o be unnecessary as this category is not regulated under this rule, perhaps they could be deleted?

Do not hesitate to contact me if you have any questions.

Sincerely,