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 Fleet 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: Proposed draft version of Placer County APCD Rule 234

Mr. Springsteen:

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

Rule 234 and apologize for the late timing of this dispatch. We view this rule as a complex 

topic, impacting customers, 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 that 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 following comments/requests:

1.) Under Definitions 216 Exempt Compounds, we would ask that you consider 

allowing TBAc to be included as an exempt solvent, preferably allowed in all refinish 

products as in San Joaquin Valley Rule 4612 (3.42) or at least as South Coast Rule

1151 (c) (33) allows in Color Coatings and Clear Coatings. This solvent would be a 

valuable tool to formulate new products without 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 possible for reducers to be used to thin all types of 

coatings (color, primers & clears...) & chemistries (enamel, urethane & latex...)

3.) Under 305, we would ask that you consider setting applicator cleaner solvents at a

maximum allowed 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 efficiently 

clean using less solvent, with minimal escape 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 packaged cleaners allow an efficient 

application of cleaning solvents - less waste, less emissions, less repeat applications.
page 2

5.) Also under 305.4, solvent for substrate cleaner limits are set in “VOC content” which I 

believe is the same as VOC Actual content; however I do not see the formula set in 

the definitions section 237 for “VOC content”.

6.) Under 501.4 facility operators are required to maintain “Purchase records identifying 

coating type, name and volume of coating”. We would ask that you consider revising 

501.4 to requiring “Purchase records identifying coating type, product name and 

volume of coating (where product data sheets or manufacturer specification sheets 

would be an acceptable medium to maintain coating type data).”

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

Again we ask that this line be changed to “Material type, coating category and 

specific use instructions (where product data sheets or manufacturer specification 

sheets would be an acceptable medium)” 

8.) Similarly, under 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, volume & type of material (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 would hope that “material type” “coating type”, “type of 

material”, “coating category” & “Applicable Use Category” listings are interchangeable 

and would be accepted in product data sheets or manufacturer specification sheets 

and of course on container labels and it would not be necessary to revise multiple 

reporting formats to accommodate a request that is already satisfied multiple times.

We might suggest if intended to be the same meaning that one term be consistently 

used, “Applicable Use Category” is commonly used in the districts.

10.) References to “Metallic Coatings” in 220 & 507.6 seem to 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,