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Final Staff Report, 01/21/10 

### 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, 09/03/2009C-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts C-3

Final Staff Report, 01/21/10 2 1 Comment Letter 1C-4 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 District response to Comment Letter 1

1. Section (C)(10) appears numbered correctly in the p reliminary draft. All numbering will be verified in final rule version for accuracy. Th e requirements of (C)(11) and (C)(11)(b) have been modified to exclude thin film inks becaus e there is no approved method to determine VOC content, and exemption (D)(5) has bee n added. 2. The cross reference in section (C)(11)(b) was in correct and has been changed to the proper reference of (B)(38).MDAQMD Rule 1117 – Graphic Arts C-5

Final Staff Report, 01/21/10 Comment Letter 2

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Final Staff Report, 01/21/10 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 i ntended meaning. 4. Section (F)(8) was added to clarify that a violatio n determined by any listed test method shall constitute a violation of the rule.C-8 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 3

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Final Staff Report, 01/21/10 4C-10 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10MDAQMD Rule 1117 – Graphic Arts C-11

Final Staff Report, 01/21/10 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 secti on (D)(2)(f) (digital printing operations) is appropriately located in the exemption section r ather than the applicability section to remain consistent with typical rule format used in the District. 3. The effective date of solvent cleaning VOC limits i n Table 7 has been changed to July 2011 for consistency with Bay Area Air Quality Mana gement District rule requirement as requested. 4. The District does not feel that a separate VOC limi t is necessary for Screen printing wipe cleaning as this method of clean-up is adequately a ddressed in section (C)(8)(b).C-12 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 4

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Final Staff Report, 01/21/10 District response to Comment Letter 4

1. Exemption (D)(6) has been added for cleaning mat erials with a VOC composite vapor pressure less than 8 mm Hg at 20 C which is consist ent with the Industrial Solvent Cleaning CTG. This will allow the operator to comp ly with all the VOC requirements of the rule.C-14 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 5

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Final Staff Report, 01/21/10 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.C-16 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 6

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Final Staff Report, 01/21/10 District response to Comment Letter 6

1. The District concurs with the clarification request ed and these sections were relocated to (D)(2). 2. The District concurs that the exemption can be expa nded to include all cleaning solvents with a vapor pressure of 8 mm Hg for consistency wi th the CTG for Industrial Cleaning Solvents.C-18 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 7

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Final Staff Report, 01/21/10C-20 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 District response to Comment Letter 7

1. Typographical errors in definition (B)(101) were ma de as noted. The markup does obscure the equal portion of the greater than or eq ual to symbol.MDAQMD Rule 1117 – Graphic Arts C-21

Final Staff Report, 01/21/10 Comment Letter 8C-22 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 1MDAQMD Rule 1117 – Graphic Arts C-23

Final Staff Report, 01/21/10 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 thi s language. In addition, there is no practical difference between “less than 300” and “3 00 or less.” The proposed language is consistent with graphic arts regulation language us ed statewide and determined to be Federal RACT.