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Appendix “C” 

Public Comments and Responses 

1. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 06/25/2009 

2. Email from USEPA, 06/25/2009 

3. Letter from Marci Kinter, SGIA, 06/26/2009 

4. Email from Harry Pontious, Victorille Daily Press, 06/29/2009 

5. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 07/09/2009 

6. Letter from Marci Kinter, SGIA, 07/20/2009 

7. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 07/28/2009 

8. CARB comment letter, 09/03/2009 
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Comment Letter 1 
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District response to Comment Letter 1 

1. Section (C)(10) appears numbered correctly in the preliminary draft. All numbering will 

be verified in final rule version for accuracy. The requirements of (C)(11) and (C)(11)(b) 

have been modified to exclude thin film inks because there is no approved method to 

determine VOC content, and exemption (D)(5) has been added. 

2. The cross reference in section (C)(11)(b) was incorrect and has been changed to the 

proper reference of (B)(38). 
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Comment Letter 2 

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District response to Comment Letter 2 

1. Section (C)(12) – Work Practices was added with the work practice requirements for 

cleaning operations as described in the CTGs. 

2. Recordkeeping requirements in section (E)(2)(a), (b) and (c) were returned to “daily.” 

3. Section (E)(2)(a)(i) was re-worded to clarify the intended meaning. 

4. Section (F)(8) was added to clarify that a violation determined by any listed test method 

shall constitute a violation of the rule. 
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Comment Letter 3 

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District response to Comment Letter 3 

1. Subsections (D)(1)(c), (d) and (e) have been moved to section (D)(2) which is more 

appropriate and clear for those reading the rule. The District believes that (D)(1)(a) and 

(b) should remain as placed. 

2. The District believes that the requirement of section (D)(2)(f) (digital printing operations) 

is appropriately located in the exemption section rather than the applicability section to 

remain consistent with typical rule format used in the District. 

3. The effective date of solvent cleaning VOC limits in Table 7 has been changed to July 

2011 for consistency with Bay Area Air Quality Management District rule requirement as 

requested. 

4. The District does not feel that a separate VOC limit is necessary for Screen printing wipe 

cleaning as this method of clean-up is adequately addressed in section (C)(8)(b). 
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Comment Letter 4 

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District response to Comment Letter 4 

1. Exemption (D)(6) has been added for cleaning materials with a VOC composite vapor 

pressure less than 8 mm Hg at 20 C which is consistent with the Industrial Solvent 

Cleaning CTG. This will allow the operator to comply with all the VOC requirements of 

the rule. 
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Comment Letter 5 

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District response to Comment Letter 5 

1. Definition (B)(101) – Thin Film UV Ink, has been added pursuant to EPA Method 24, 

11.1.5, 12.1, and 12.2. 
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Comment Letter 6 

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District response to Comment Letter 6 

1. The District concurs with the clarification requested and these sections were relocated to 

(D)(2). 

2. The District concurs that the exemption can be expanded to include all cleaning solvents 

with a vapor pressure of 8 mm Hg for consistency with the CTG for Industrial Cleaning 

Solvents. 
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Comment Letter 7 

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District response to Comment Letter 7 

1. Typographical errors in definition (B)(101) were made as noted. The markup does 

obscure the equal portion of the greater than or equal to symbol. 
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Comment Letter 8 
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District response to Comment Letter 8 

1. The District has no operation that is subject to the 300 g/L limit. Therefore there will be 

no change (or increase) of VOC emissions due to this language. In addition, there is no 

practical difference between “less than 300” and “300 or less.” The proposed language is 

consistent with graphic arts regulation language used statewide and determined to be 

Federal RACT.