GISIR American Coatings 

March 24, 2011 

Ms. Barbara Hoffman 

Dept. of Environmental Services 

29 Hazen Drive; P .O. Box 95 

Concord, NH 03302-0095 

RE: NH Volatile Organic Compounds (VOCs) Reasonably Available 

Control Technology (RACT) ; Rule Env-A 1200; ACA Comments 

Dear Ms. Hoffman: 

The American Coatings Association (ACA) ' submits the following comments on proposed Rule 

Env-A 1200 . 

PART Env-A 1214 Flat Wood Panelin2 Coatings - Section Env-A 1214.02 (c) 

ACA suggests the following edit: 

"(c) An emission limit of 2.1 pounds of VOC per gallon of sokWs-s-finsert material], equivalent to 

250 grams of VOC per liter of material, excluding water and exempt compounds. 

PART Env-A 1221 . 08 Compliance Standards for the Use of Industrial Cleaning Solvents 

ACA has been actively working with a number of States to adopt reasonable Industrial Cleaning 

Solvent regulations for coatings, inks, adhesives and resin manufacturing operations . As we 

mentioned in the attached 1/6/2011 letter to the Ozone Transport Commission (OTC) - the 50 g/1 

VOC limit would not allow effective cleaning at coatings, inks, adhesives and resin 

manufacturing operations . We recommend NH adopt similar language that WI, IL, OH and IN 

are currently adopting (similar to the suggested language we included in our OTC letter) , as 

outlined below (this is the proposed OH language) : 

"(b) In lieu of complying with the requirements in Section Env - A 1221 .08 (b) and (c) 

1 The American Coatings Association (ACA) is a voluntary, nonprofit trade association working to advance the 

needs of the paint and coatings industry and the professionals who work in it. The organization represents p aint and 

coatings manufacturers, raw materials suppliers, distributors, and technical professionals. ACA serves as an 

advocate and ally for members on legislative, regulatory and judicial issues, and provides forums for the 

advancement and promotion of the industry through educational and professional development services . 

1500 RHODE ISLAND AVENUE N.w. - WASHINGTON, DC 20005 " T 202.462 .6272 " F 202.462 .8549 " www.paint .org 
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of this rule, a manufacturer of coatings, inks, resin, or adhesives may comply with the following 

requirements : 

(i) Clean portable or stationary mixing vats, high dispersion mills, grinding mills, tote 

tanks and roller mills by one or more of the following methods: 

(a) Use a cleaning solvent that either contains less than 1 .67 

pounds per gallon of VOC or has a composite vapor 

pressure no more than eight mmHg at twenty degrees 

Celsius; 

(b) Comply with the following work practices : 

(i) Equipment being cleaned must be maintained leak free ; 

(ii) VOC-containing cleaning materials must be drained 

from the cleaned equipment upon completion of 

cleaning; 

(iii) VOC-containing cleaning materials, including waste 

solvent, shall not be stored or disposed of in such a 

manner that will cause or allow evaporation into the 

atmosphere ; and 

(iv) Store all VOC-containing cleaning materials in closed 

containers . 

(c) Collect and vent the emissions from equipment cleaning to a 

VOC emission control system that has an overall capture and control efficiency of 

at least eighty per cent, by weight, for the VOC emissions. Where such redu ction 

is achieved by incineration, at least ninety per cent of the organic carbon shall be 

oxidized to carbon dioxide. 

(d) Use organic solvents other than those allowed in paragraph Env -A 1221 .08 

(c)(1) of this rule provided no more than sixty gallons of fresh solvent shall be 

used per month. Organic solvent that is reused or recycled (either on -site or offsite), for further use in equipment cleaning or the manufacture of coating, ink, or 

adhesive shall not be included in this limit. Also, store all VOC-containing cleaning materials in closed containers . 

(ii) When using solvent for wipe cleaning, the owner or operator of a 
facility shall: 

(a) Not use open containers for the storage or disposal of cloth or 

paper impregnated with organic compounds that is used for 

cleanup, or coating, ink, or adhesive removal; and 

(b) Not store spent or fresh organic compounds to be used for 

cleanup or coating, ink, resin, or adhesive removal in open 

containers." 

Further, below is the OH proposed recordkeeping requiremen ts as well: 

"Any manufacturer of coatings, inks, resin, or adhesives that complies with 

paragraph (b)(i)(d) of this rule, shall record the following information each month 

for each cleaning material and shall maintain the information at the facility for a 

period of five years: 

(a) The total volume of fresh cleaning solvent material used for equipment 

cleaning ; and 

(b) The total volume of cleaning solvent material recovered for either on -

site or off-site recycling." 

If you have any questions on the langu a 

Braun [Paul.Braun@epa.state .oh.us] 

Rosenthal .St even(cr~epamail .eppa .gov . 

e - please contac 

Steven Rosenthal at EPA Region 5, (312) 886 -6052 

Thank you for the opportunity to comment. If you have any questions or need any further 

information on the issues discussed here, please feel free to contact me at (202) 462 -6272. 

Sincerely, 

054-es 

David Darling, P.E. 

Senior Director, Environmental Affairs 

Cc: Kent C Hustvedt, EPA 

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