# pennsylvania

DEPARTMENT OF ENVIRONMENTAL PROTECTION SECRETARY July 16, 2014

Shawn M. Garvin Regional Administrator U.S. Environmental Protection Agency, Region III 1650 Arch Street (Mail Code: 3RAOO) Philadelphia, PA 19103-2029 Dear Mr. Garvin: OnNovember 15, 2013, the PennsylvaniaDepartment ofEnvironmental Protection (DEP) submitted a revision to Pennsylvania's State ImplementationPlan (SIP) pertaining to the adoption byAllegheny County Health Department (ACHD) inJune 2013 offour separate regulations implementing Control Techniques Guidelines (CTG) issued bythe U.S. Environmental Protection Agency (EPA) in 2008 for Miscellaneous Metal and/or Plastic Parts Surface Coating Processes; Automobile and Light-Duty Truck Assembly Coatings; Miscellaneous Industrial Adhesives; and Fiberglass BoatManufacturing Materials. The revision is identified as revision 74 for ACHD's internal tracking. The EPA reviewed the SIP revision. As a result ofits review, EPA indicatedthat Section 2105.86 (relating to Control ofVOC Emissions from Fiberglass BoatManufacturing Materials) referenced Table 2105.86 (average monomer VOC content limit), but Table 2105.86 was not included inthe submittal. ACHD subsequentlyreportedthat the table had notbeen included as part ofthe regulationthatwent outto public hearing. This omission is inconsistent with EPA's procedures for SIP revisions set forth at 40 C.F.R. § 51.102(d)(2), whichrequires the availability ofthe entire planfor public inspection. The table ofVOC emission limits is a significantpart ofthe regulation and, without the table available for public inspection, meaningful public comment is difficult. ACHD must comply with state and federal requirements for notice and comment. To address the situation, EPA offered a "conditional approval" ofthe SIP submittal under CleanAirAct Section 11O(k)(4) ifACHD, within one year, amends and submits a revised Section 2105.86 to EPA. Withthis understanding, ACHD has committedto DEP to promptlyrevise Article XXI, Section 2105.86, by adding Table 2105.86 (enclosed for your information) to satisfy the issues discussed above. DEP will submit this change to EPA within one year from the FederalRegister publication offinal notice ofconditional approval.

Rachel Carson State Office Building I P.O

. Box 2063 1 Harrisburg, PA 17105-2063 717.787.2814

**~** Printed on Recycled Paper 

### \6{f] www.depweb.state.pa.us

### Mr. Shawn M. Garvin
- 2- July 16, 2014



### DEP andACHD are confident that this commitment can be met for the following reasons: (1) 

### The amount oftechnical work necessary for the measure to be adopted is minimal. The content ofthe table already exists inthe CTG and mustmerely be placed into Article XXI, Section 2105.86. (2) Adoption ofthe measure is not expectedto be controversial because there are no related regulated sources inAllegheny County. (3) The regulationrevision canbe adopted atthe county level, andreviewed by DEP and forwarded to EPA, in less than one year. DEP understands thatthis commitmentwill result in a conditional approval byEPA ofthe previously submitted CTG SIP revision 74 for Allegheny County. UponEPA's approval ofthe SIP revision satisfyingthe rulemaking commitments, EPA's conditional approval will become a full approval. Should youhave questions or need additional information, please contactJoyce E. Epps, Director, Bureau ofAir Quality, by e-mail atjeepps@pa.gov orbytelephone at 717.787.9702. You may also contactJayme Graham, Manager, ACHD Air Quality Program, by e-mail at jgraham@achd.net orbytelephone at412.578.8103. Sincerely, 

# £_

# c£

**~-j ry**  E. ChristopherAbruzzo Secretary Enclosures

### ATTACHMENT

Table 2105.86 MonomerVOC ContentLimitations for OpenMoldingResin and Gel Coat Operations Material
Production Resin ProductionResin Pigmented Gel Coat Clear Gel Coat Tooling Resin Tooling Resin Tooling Gel Coat 

### Application Method WeightAverageMonomerVOC ContentLimit (weight percent) Atomized (spray) 

### 28 Nonatomized 

### 35 AnyMethod 

### 33 Any Method 

### 48 Atomized 

### 30 Nonatomized 

### 39 Any Method 

### 40

# COUNTYOF

Ms. Joyce Epps, Director Bureau ofAir Quality RICH FITZGERALD COUNTY EXECUTIVE 

### June 26, 2014

Department ofEnvironmental Protection Rachel Carson Building 400 Market Street P 

### 0 Box 8468 Harrisburg, PA 17105-8468 Dear Ms. Epps: 

# ALLEGHENY

Thepurpose ofthis letter is to request your assistance with an action pending before the U.S. Environmental Protection Agency (EPA) concerning the State Implementation Plan (SIP) Revision for the Allegheny County Health Department's Fiberglass Boat Manufacturing Materials regulation. OnNovember 15, 2013, the Pennsylvania Department ofEnvironmental Protection (DEP) submitted a revisionto Pennsylvania's State Implementation Plan (SIP) pertaining to the adoption by the Allegheny County Health Department (ACHD) in June 2013 offour separate regulations implementing Control Techniques Guidelines (CTGs) promulgated by the U.S. Environmental Protection Agency (EPA) in 2008 for Miscellaneous Metal and/or Plastic Parts Surface Coating Processes; Automobile and Light-Duty Truck Assembly Coatings; Miscellaneous Industrial Adhesives; and Fiberglass Boat Manufacturing Materials. The revision is identified as revision No. 74 to the Attainment and Maintenance Plan for ACHD's internal tracking. As a result ofits review, EPAhas indicatedthat: (1) 

### In Section 2105.86, "Control ofVOC Emissions from Fiberglass Boat Manufacturing Materials," under Subsection c, "Limitations;" Table 2105.86 (regarding average monomer VOC content limit) is referenced, but the table is not included in the submittal. (2) Given that ACHD subsequently reported thatthe table had not been included as part of the regulation that went outto public hearing, this omission is inconsistent with EPA's procedures for SIP revisions set forth at 40 C.F.R. §51.102(d)(2) which requires the availability ofthe entire plan for public inspection, including thattable. (3) The table ofVOC emission limits is a significantpart ofthe regulation, and it is difficult for meaningful public comment ifthose emission limits are not available for public inspection, and ACHDmust comply with state and federal requirements for notice and comment.

ALLEGHENY COUNTY HEALTH DEPARTMENT • AIR QUALITY PROGRAM 301 39TH STREET BUILDING #7 • PITTSBURGH. PA 15201-1 81 1 PHONE (4 12) 57&81 03 • FAX (4 12) 57&81 44

### To address the situation, EPA has offered a "conditional approval" ofthe SIP submittal under Clean Air Act section 110(k)(4) during which time ACHD would within one year amend and submit a revised Section 2105.86 to EPA. Withthis U!J.derstanding, Allegheny County is requesting that you seek the Secretary's concurrence and signature in a letterto the EPA Region III Administrator committing ACHD to revising Article XXI, Section 2105.86, which is before EPA for action pursuant to Section 110(k) ofthe Clean Air Act, by adding Table 2105.86 (shown in the attachment) within one year from the Federal Registerpublication affinal notice ofconditional approval ofACHD's CTG SIP 74. In turn, 

### ACHD commits to revising Article XXI Section 2105.86 in a timely fashion that will allow DEP adequate time to review and submit the revised SIP to EPA within the one year time frame described above. ACHD is confident thatthis commitment can be met for the following reasons. (1) The amount oftechnical work necessary for the measure to be adopted is minimal. The content ofthe table already exists in the CTG and must merely be placed into Article XXI, Section 2105.86. (2) Adoption ofthe measure is not expected to be controversial because there are no related regulated sources in Allegheny County. (3) The regulation revision can be adopted at the County level, and reviewed by PA DEP and forwarded to EPA in less than one year. ACHD understands that this commitment will result in a conditional approval by EPA ofthe previously submitted CTG SIP revision No. 74 for Allegheny County. Upon EPA's approval of the SIP revision satisfying the rulemaking commitments, EPA's conditional approval to the Allegheny portion ofthe Pennsylvania SIP will become a full approval. EPA request prompt action so that final action may be taken onthe SIP revision. Thank you for your assistance inthis matter.

cc: Kirit Dalal Steve Hepler Enclosures: • Attachment 

# 6W~~ Jayme Graham, Manager Air Quality Program

### ATTACHMENT

Table 2105.86 Monomer VOC ContentLimitations for Open Molding Resin and Gel Coat Operations Material

Production Resin Production Resin Pigmented Gel Coat Clear Gel Coat Tooling Resin Tooling Resin Tooling Gel Coat 

### Application Method WeightAverage MonomerVOC ContentLimit (weight percent) Atomized (spray) 

### 28 Nonatomized 

### 35 Any Method 

### 33 Any Method 

### 48 Atomized 

### 30 Nanatomized 39 Any Method 

### 40

# COUNTYOF

Ms. Diana Esher, Director Air Protection Division Region III (3APOO) U.S. Environmental Protection Agency 1650 Arch Street Philadelphia, PA 19103-2029

Dear Ms. Esher: RICH FITZGERALD COUNTY EXECUTIVE
June 26,2014 

# ALLEGHENY

On November 15, 2013, the Pennsylvania Department ofEnvironmental Protection (DEP) submitted a revision to Pennsylvania's State Implementation Plan (SIP) pertaining to the adoption by the Allegheny County Health Department (ACHD) in June 2013 offour separate regulations implementing Control Techniques Guidelines (CTGs) promulgated by the U.S. Environmental Protection Agency (EPA) in 2008 for Miscellaneous Metal and/or Plastic Parts Surface Coating Processes; Automobile and LightDuty Truck Assembly Coatings; Miscellaneous Industrial Adhesives; and Fiberglass Boat Manufacturing Materials. The revision is identified as revision No. 74 to the Attainment and Maintenance Plan for ACHD's internal tracking. As a result ofits review, EPA has indicated that: (1) In Section 2105.86, "Control ofVOC Emissions from Fiberglass Boat Manufacturing Materials," under Subsection c, "Limitations,"Table 2105.86 (average monomer VOC content limit) is referenced, butthe table is not included in the submittal. (2) Given that ACHD subsequently reported thatthe table had not been included as part ofthe regulation that went outto public hearing, this omission is inconsistent with EPA's procedures for SIP revisions set forth at 40 C.F.R. §51.102(d)(2) which requires the availability ofthe entire plan for public inspection, includingthat table. (3) The table ofVOC emission limits is a significant part ofthe regulation, and it is difficult for meaningful public comment ifthose emission limits are not available for public inspection, and ACHD must comply with state and federal requirements for notice and comment. To address the situation, EPA has offered a "conditional approval" ofthe SIP submittal under Clean Air Act section 110(k)(4) during which time ACHD would within one year amend and submit a revised Section 2105.86 to EPA. With this understanding, Allegheny County intends to submit a letter through the Pennsylvania Department ofEnvironmental Protection committing to revising Article XXI, Section 21 05.86, which is before EPA for action pursuantto Section 11O(k) ofthe Clean Air Act, by adding Table 2105.86 (shown below) within one year from the Federal Register publication offinal notice ofconditional approval to ACHD's CTG SIP 74.

ALLEGHENY COUNTY HEALTH DEPARTMENT • AIR QUALITY PROGRAM 301 397 " STREET BUILDING #7 • PITTSBURGH, PA i 5201-181 1 PHONE (41 2) 578-8103 • FAX (41 2) 578-81 44ACHD is confidentthatthis commitment can be met for the following reasons. (1) The amount oftechnical work necessary for the measure to be adopted is minimal. The content of the table already exists in the CTG and must merely be placed into Article XXI, Section 2105

.86. (2) Adoption ofthe measure is not expected to be controversial becausethere are no related regulated sources in Allegheny County. (3) The regulation revision can be adopted atthe County level, and reviewed by PA DEP and forwarded to EPA in less than oneyear.
Table 2105.86 MonomerVOC ContentLimitations for Open MoldingResin and Gel Coat Operations Material

Production Resin Production Resin Pigmented Gel Coat Clear Gel Coat Tooling Resin ToolingResin Tooling Gel Coat Application Method

Atomized (spray) Nonatomized Any Method Any Method Atomized Nonatomized Any Method Weight Average Monomer VOC ContentLimit (weight percent) 28 

### 35 33 48 30 39 40

ACHD understands thatthis commitmentwill result in a conditional approval by EPA ofthe previously submitted CTG SIP revision No. 74 for Allegheny County. Upon EPA's approval ofthe SIP revision satisfyingthe rulemaking commitments, EPA's conditional approval to the Allegheny portion ofthe Pennsylvania SIP will become a full approval. This will be done promptly

.

cc: Ms

. Joyce Epps, Pennsylvania DEP Ms. Irene Shandruk, U.S. EPA