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, MA 02114-2023 

Dear Mr. Conroy: 

The Office of Air 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, "Petroleum Liquids 

Marketing and Storage," allows gasoline dispensing facilities that exclusively fuel rental cars or 

corporate or commercial fleets to apply for exemption from Stage II vapor recovery 

requirements, consistent with EPA guidance, and requires annual testing of pressure 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 from Organic 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. 

A public 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 fiber 
The following support documents are included in this submittal package : 

1 . A Notice of Public Hearing, Mailing List, and Affidavit of Publication for the hearing 

notice, which was published on 8 July 2208; 

2. A transcript of the Public Hearing; 

3 . A copy of the hearing officer's Decision; and 

4. A copy 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 from the 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, EPA Region 1 asked that RI 

DEM include information in its SIP revision submittal on the number and throughput of stations 

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. = 2,400 gals./month 

If you have any questions about this submittal, please contact me at (401) 222-2808 ext. 7012. 

Very truly yours, 

Barbara Morin, Supervising Environmental Scientist 

Office of Air Resources