3R Comments Solvent Degreasing 041511

April 15, 2011
Alexander Ryan-Bond
Environmental Associate
Ozone Transport Commission
444 North Capitol St. NW, Suite 638
Washington, DC 20001
[email protected]
Subject: Solvent Degreasing
Raymond Regulatory Resources (3R) appreciates the opportunity to comment on the Ozone
Transport Commission (OTC) proposed Model Rule on Solvent Degreasing. In addition 3R
appreciates the efforts of the OTC to delay the adoption of this Model Rule to accept
supplemental comments as discussed in the March 16 meeting in Baltimore.
During the meeting Ali Mirzakhalili requested the need for the industry to supply specific
changes that are needed to the rule. On February 28, 2011, 3R sent correspondence to you on
this Model Rule. In an effort to not repeat these issues, the following suggestions are in response
to Mr. Mirzakhalili plea for specific changes. Reasoning for these changes were detailed in my
February 28 letter which was based on a review of District regulations in California.
The Model Rule 2011 should add the following
Exempt up to 110 gallons per year of non-compliant solvent usage per establishment.
Exempt niche applications for the following
o Medical
o Optics
o Electronics
o Aerospace
o Precision cleaning
Provide an alternative Reactivity limit using Maximum Incremental Reactivity limit
Exempt Aerosol Products from the rule
Incorporating the above changes will lesson the regulatory burden on smaller and specialty
establishments as well as lesson the enforcement challenges for the agency on small volume
Thank you for your attention to this issue and I look forward to working with you on this. Any
questions or comments feel free to call or e-mail.
Doug Raymond
Raymond Regulatory Resources (3R), LLC
Home office: 440-474-4999
Mobile: 440-339-4539
[email protected]