# GISIR AmericanCoatings

March 24, 2011 Ms. Barbara Hoffman Dept . of Environmental Services 29 Hazen Drive; P.O

. Box 95 Concord, NH03302-0095 RE: NHVolatile Organic Compounds (VOCs) Reasonably Available Control Technology (RACT) ; Rule Env-A1200 ; 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) ACAsuggests the following edit: "(c) An emission limit of2.1 pounds ofVOC pergallon ofsokWs-s-finsert material], equivalent to 250grams of VOCper liter ofmaterial, excluding water andexempt compounds. PART Env-A 1221 . 08Compliance 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 OTCletter) , as outlined below

(this is the proposed OHlanguage) : "(b) In lieu of complyingwith 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 ofthe paint and coatings industry and the professionals who work in it. The organization represents p aint and coatings manufacturers, raw materials suppliers, distributors, andtechnical professionals. ACAserves as an advocate and ally for members on legislative, regulatory andjudicial 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

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of this rule, amanufacturer 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 VOCor has a composite vapor pressure no more than eight mmHg at twe ntydegrees 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 fromthe 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 allowevaporation into the atmosphere; and (iv) Store all VOC-containing cleaning materials in closed containers
. (c) Collect and vent the emissions fromequipment cleaning to a VOCemission control systemthat has an overall capture and control efficiency of at least eighty per cent, by weight, for the VOCemissions. 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) ofthis 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 afacility 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, belowis the OHproposed 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 ofcleaning 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 EPARegion 5, (312 ) 886 -6052 Thank you for the opportunity to comment. Ifyou 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 CHustvedt, EPA ** Sentvia email **