ADDTIONALSTAKEHOLDERCOMMENT-2021-08-06.PDF

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Subject:
FW: Online Form Submittal: Citizen Comments
Attachments:
RadTech Public Comments Rule 336 080621.pdf
From: noreply@civicplus.com <noreply@civicplus.com>  
Sent: Friday, August 6, 2021 2:50 PM 
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (COA) <Kathy.Semder@Maricopa.Gov>; Andy 
Linton (OBM) <Andy.Linton@Maricopa.Gov>; Bill Leal (OBM) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (OBM) 
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (ENV) <Blanca.Caballero@Maricopa.gov> 
Subject: Online Form Submittal: Citizen Comments 
Citizen Comments 
Each Regulatory Department is committed to providing opportunities for 
stakeholder input regarding the adoption and amendment of all regulatory 
requirements. Your input will be collected and forwarded to the appropriate 
department. You will receive a written response from the applicable department 
within two business days. We appreciate your comments and your time. 
Case Number/Rule 
AQ-2017-008 Rule 336 Surface Coating Operations 
Department 
Air Quality
I would like to  
Express opposition
First Name 
Rita
Last Name 
Loof
Organization 
RadTech International
City 
Upland
Zip 
91784
Email 
rml93@verizon.net 
Phone Number 
909-240-0866
Phone Type 
Mobile
Would you like someone to 
contact you? 
Yes 
Comments 
OPPOSE unless Amended Rule 336-- Surface Coating;

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supporting documentation 
associated with your 
comment. The only file 
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RadTech Public Comments Rule 336 080621.pdf
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The Honorable Supervisors 
Maricopa County  
August 6th, 2021 
Re:  Public Comments Rule 336—Surface Coating Operations—OPPOSE unless Amended 
RadTech is pleased to comment on Maricopa County’s proposed amendments to Rule 336 --
Surface Coating Operations. 
Introducing RadTech and UV/EB/LED 
RadTech International is the trade association for the Ultraviolet/ Electron Beam/Light Emitting 
Diode (UV/EB/LED) industry.  The organization represents over 800 members nationwide 
involved in a myriad of markets ranging from solar panel manufacturing to finger nail polish.  
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, they are 
specifically formulated to react to UV light or a beam of electrons.  The nature of the process is 
such that virtually no Volatile Organic Compounds (VOCs) are generated. The materials are 
generally high viscosity and thus there are no regulatory concerns with generation of particulate 
matter from spraying.  Additionally, UV/EB processes are electric and thus do not produce 
combustion contaminants such as NOx, SOx and Greenhouse Gases. 
The South Coast Air Quality Management District has some of the most stringent air quality 
regulations in the nation. In many of its rulemakings, the agency has recognized the 
sustainability advantages, including energy efficiency, of ultraviolet and electron beam curing 
technology.  SCAQMD provides incentives to companies who convert to UV/EB through 
exemptions from permitting and recordkeeping. The agency recognized UV/EB as Best 
Available Control Technology for many industry sectors and the technology has recently been 
included in the Statewide BACT Clearinghouse for the California Air Resources Board. 
UV/EB technology meets the regulatory definition of “super-compliant” in the SCAQMD which 
applies to coatings with a Volatile Organic Compound (VOC) content of less than 50 grams per 
liter.  RadTech holds a seat on the South Coast Air Quality Management Plan Advisory 
Committee.  Our Association provides input to the agency on how to achieve clean air goals and 
implementation of UV/EB is one strategy which has been included in the Air Quality 
Management Plan. The most recent AQMP now includes UV/EB as control strategy. According 
to SCAQMD findings: “These programs may also provide manufacturers with incentives to 
accelerate the deployment of cleaner technologies.  Such an example is the use of energy-curing

technologies which includes ultraviolet light (UV), electron beam (EB), heat and light emitting 
diode (LED) cured coatings. 
The California State Senate has adopted a resolution recognizing the many benefits of ultraviolet 
(UV) and electron beam (EB) technologies and the contributions of RadTech. The proclamation 
acknowledges the “invaluable” contributions made by RadTech to the State of California and 
beyond, and cites the Association’s ideals of community service. It commends RadTech for its 
“outstanding commitment to improving the environment and economy through its programs.” 
The Environmental Protection Agency has classified UV/EB technology as Lowest Achievable 
Emission Rate. The EPA Control Techniques Guidelines documents state: “This technology is 
gaining greater acceptance and, where applicable, achieves a near 100 percent reduction of VOC 
emissions”. 
With UV/EB technology, facilities can achieve emission reductions above and beyond those 
required by even the most stringent of regulations. There is no need to install air pollution 
control devices which may emit combustion contaminants such as Nitrogen Oxides or Sulfur 
Oxides. The products do not contain Toxic Air Contaminants and have no secondary adverse 
impacts such as emissions of greenhouse gases.  
Requested Proposed Rule Language Changes 
RadTech believes that Rule 336 presents an opportunity for Maricopa County to achieve 
voluntary emission reductions above and beyond those presently required in the rule, through 
regulatory flexibility that will encourage conversion to UV/EB/LED.   
Request for Exemption 
Our materials are typically well below 50 grams/liter in VOC content which is minimal 
compared to the proposed limits.  We respectfully request that UV/EB/LED materials be 
exempted from the rule requirements.  An exemption would be an incentive for businesses to 
voluntarily choose UV/EB/LED technology resulting in additional emission reductions for 
Maricopa County.   
Recordkeeping requirements are burdensome on businesses and in the case of UV/EB/LED 
operations, are not crucial because the materials are well below the rule limits.  Exempting 
energy curable materials from overly prescriptive recordkeeping requirements will alleviate 
regulatory burdens on the Maricopa County business community and benefit air quality.  
Definition  
We would very much appreciate the inclusion of a definition for energy curable materials in the 
rule.  We propose a definition like the one in SCAQMD rules: 
ENERGY CURABLE MATERIALS are single component reactive products that cure upon 
exposure to visible-light, ultraviolet light, or to an electron beam.

Test Method 
The Environmental Protection Agency and the SCAQMD have long recognized that EPA 
Method 24 is not suitable for thin film UV/EB/LED Materials.  Thus, RadTech urges Maricopa 
County to include ASTM D7767-11 as suitable test method for UV/EB/LED products subject to 
Rule 336.  We propose the following language:  
The VOC content of thin film Energy Curable Adhesives and Sealants may be determined by 
manufacturers using ASTM Test Method 7767 Standard Test Method to Measure Volatiles from 
Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from 
Them. 
Transfer Efficiency 
UV/EB/LED products have higher viscosities than conventional solvent products.  The rationale 
behind transfer efficiency requirements is to control VOC emissions that can take place during 
spraying operations.  But, given the fact that UV/EB/LED materials do not have emissions like 
conventional solvent processes, facilities should not be required to the same level of regulation 
for transfer efficiency purposes. We urge Maricopa County to exempt UV/EB/LED materials 
with viscosities of 650 centipoise or above, from the transfer efficiency requirements of the rule. 
UV/EB materials not only meet, but far exceed any proposed rule requirements and any added 
flexibility to companies that choose these pollution preventive processes will encourage 
voluntary emission reductions thereby furthering the County’s mission. 
The RadTech Association looks forward to working with the Board of Supervisors of Maricopa 
County on this rulemaking and would gladly provide any additional information your staff may 
need. 
Sincerely, 
 
Rita M. Loof 
Director, Environmental Affairs