RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 235 Promenade Street, Providence, R102908-5767 TDD 401-222-4462 22 September 2008 David Conroy EPA- New

England, Region I 1 Congress Street, Suite 1100 Boston, MA02114-2023 Dear Mr. Conroy: The Office ofAir Resources (OAR) is hereby submitting the "Providence Carbon Monoxide Limited Maintenance Plan" and amendments to the "Rhode Island Air Pollution Control General Definitions" regulation and to Rhode Island Air Pollution Control (RI APC) Regulation Nos. 9, 11 and 36 as formal revisions to the Rhode Island State Implementation Plan (SIP) . The "Providence Carbon Monoxide Limited Maintenance Plan" specifies measures that will ensure that Providence remains in attainment of the National Ambient Air Quality Standard for carbon monoxide through 2011 . The revision to Regulation No. 11, "PetroleumLiquids Marketing and Storage," allows gasoline dispensing facilities that exclusively fuel rental cars or corporate or commercial fleets to apply for exemption fromStage II vapor recovery requirements, consistent with EPA guidance, and requires annual testing ofpressure vacuum caps on Stage II systems. The Minimum Quantity thresholds in Regulation No. 9, "Air Pollution Control Permits," were updated to be consistent with those in concurrent amendments to the state's air toxics regulation, Regulation No. 22. The revision to regulation No. 36, "Control of Emissions fromOrganic Solvent Cleaning," exempts cold cleaners using solvents containing 5% or less volatile organic compounds and volatile hazardous air pollutants, clarifies work practice and reporting requirements, further regulates vapor cleaners using trans 1,2-dichloroethylene or n-propyl bromide and adopts EPA's facility-wide emissions limits. The revision also adopts the Ozone Transport Commission's vapor pressure limit for cold cleaning solvents, consistent with the commitments in Rhode Island's attainment demonstration for the 8-hour ozone standard. . The General Definitions regulation was amended to include definitions consistent with the updates in Regulations No. 22 and 36 . Apublic notice announcing a public comment period and hearing on the proposed adoption of the plan and amended regulations was published in the Providence Journal-Bulletin on 8 July 2008. The hearing was held on 8 August 2008.

~L# 30% post-consumer fiberThe following support documents are included in this submittal package:

1 . ANotice of Public Hearing, Mailing List, and Affidavit of Publication for the hearing notice, which was published on 8July 2208; 2 . Atranscript of the Public Hearing; 3. Acopy of the hearing officer's Decision; and 4 . Acopy of the final plan and amended regulations, including revisions noted in the Decision; Please note that, in Regulation No. 36, subpart 36.2.2 was deleted fromthe submitted regulation. That subpart reads as follows: 36.2.2 Wherever the term"Volatile Organic Compound" or "VOC" appears in Subsection 36.1 .18 or Sections 36.2 through 36.12, read this to mean "Volatile Organic Compounds and Halogenated Organic Compounds" or "VOC and HOC" . In your comments on the proposed revisions to Regulation No. 11, EPARegion 1 asked that RI DEM include information in its SIPrevision submittal on the number and throughput ofstations that have been granted an exemption to Stage II requirements under a provision in that regulation that allows a new

or substantially modified facility to request an exemption if it dispenses less than 10,000 gallons of gasoline per month and demonstrates that Stage II controls are not technically and/or economically feasible. Only two stations have received exemptions under that provision. Those stations and their throughputs are as follows: " Veterans Administration Medical Center - highest throughput . = 957 gals./month and " Kent County Water Authority - highest throughput . = 2,400gals./month Ifyou have any questions about this submittal, please contact me at (401) 222-2808 ext. 7012. Very truly yours,

Barbara Morin, Supervising Environmental Scientist Office ofAir Resources