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: 

On November 15, 2013, the Pennsylvania Department of Environmental Protection (DEP) 

submitted a revision to Pennsylvania's State Implementation Plan (SIP) pertaining to the 

adoption by Allegheny County Health Department (ACHD) in June 2013 of four separate 

regulations implementing Control Techniques Guidelines (CTG) issued 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 74 for ACHD's internal tracking. 

The EPA reviewed the SIP revision. As a result of its review, EPA indicated that 

Section 2105.86 (relating to Control ofVOC Emissions from Fiberglass Boat Manufacturing 

Materials) referenced Table 2105.86 (average monomer VOC content limit), but Table 2105.86 

was not included in the submittal. ACHD subsequently reported that the table had not been 

included as part of the regulation that went out to 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 of the entire plan for public inspection. The table ofVOC emission limits is a 

significant part of the 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 

Clean Air Act Section 11 O(k)( 4) if ACHD, within one year, amends and submits a revised 

Section 2105.86 to EPA. 

With this understanding, ACHD has committed to DEP to promptly revise 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 Federal Register 

publication of final notice of conditional 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 and ACHD are confident that this commitment can be met for the following reasons: 

(1) The amount of technical 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 of the 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 DEP and 

forwarded to EPA, in less than one year. 

DEP understands that this commitment will result in a conditional approval by EPA ofthe 

previously submitted CTG SIP revision 74 for Allegheny County. Upon EPA's approval ofthe 

SIP revision satisfying the rulemaking commitments, EPA's conditional approval will become a 

full approval. 

Should you have questions or need additional information, please contact Joyce E. Epps, 

Director, Bureau of Air Quality, by e-mail atjeepps@pa.gov or by telephone at 717.787.9702. 

You may also contact Jayme Graham, Manager, ACHD Air Quality Program, by e-mail at 

jgraham@achd.net or by telephone at 412.578.8103. 

Sincerely, 

£_ c£ ~-j ry E. Christopher Abruzzo 

Secretary 

Enclosures 
ATTACHMENT 

Table 2105.86 

Monomer VOC Content Limitations 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 Weight Average Monomer VOC Content Limit 

(weight percent) 

Atomized (spray) 28 

Nonatomized 35 

Any Method 33 

Any Method 48 

Atomized 30 

Nonatomized 39 

Any Method 40 
COUNTY OF 

Ms. Joyce Epps, Director 

Bureau of Air Quality 

RICH FITZGERALD 

COUNTY EXECUTIVE 

June 26, 2014 

Department of Environmental Protection 

Rachel Carson Building 

400 Market Street 

P 0 Box 8468 

Harrisburg, P A 171 05-8468 

Dear Ms. Epps: 

ALLEGHENY 

The purpose of this 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. 

On November 15, 2013, the Pennsylvania Department of Environmental 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 of four 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 of its 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 (regarding average 

monomer VOC content limit) is referenced, but the table is not included in the submittal. 

(2) Given that ACHD subsequently reported that the table had not been included as part of 

the regulation that went out to public hearing, this omission is inconsistent with EPA's 

procedures for SIP revisions set forth at 40 C.F.R. §51.1 02( d)(2) which requires the 

availability of the entire plan for public inspection, including that table. 

(3) The table ofVOC emission limits is a significant part of the regulation, and it is difficult 

for meaningful public comment if those emission limits are not available for public 

inspection, and ACHD must comply with state and federal requirements for notice and 

comment. 

ALLEGHENY COUNTY HEALTH DEPARTMENT • AIR QUALITY PROGRAM 

301 39TH STREET BUILDING #7 • PITTSBURGH. PA 1 5201-1 81 1 

PHONE (4 1 2) 57&81 03 • FAX (4 1 2) 57&81 44 
To address the situation, EPA has offered a "conditional approval" of the SIP submittal under 

Clean Air Act section 110(k)(4) during which time ACHD would within one year amend and 

submit a revised Section 21 05.86 to EPA. 

With this U!J.derstanding, Allegheny County is requesting that you seek the Secretary's 

concurrence and signature in a letter to the EPA Region III Administrator committing ACHD to 

revising Article XXI, Section 21 05. 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 Register publication affinal notice of conditional approval of ACHD'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 that this commitment can be met for the following reasons. 

(1) The amount of technical 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 of the 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 of the 

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 on the SIP revision. 

Thank you for your assistance in this matter. 

cc: Kirit Dalal 

Steve Hepler 

Enclosures: 

• Attachment 

Jayme 

6W~~ Graham, Manager 

Air Quality Program 
ATTACHMENT 

Table 2105.86 

Monomer VOC Content Limitations 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 Weight Average Monomer VOC Content Limit 

(weight percent) 

Atomized (spray) 28 

Nonatomized 35 

Any Method 33 

Any Method 48 

Atomized 30 

N anatomized 39 

Any Method 40 
COUNTY OF 

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 of Environmental 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 of four 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 of its 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, but the table is not included in the submittal. 

(2) Given that ACHD subsequently reported that the table had not been included as part of the 

regulation that went out to 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 that table. 

(3) The table ofVOC emission limits is a significant part of the regulation, and it is difficult for 

meaningful public comment if those 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" of the 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 of Environmental Protection committing to revising Article XXI, Section 21 05. 86, which is 

before EPA for action pursuant to Section 11 O(k) of the Clean Air Act, by adding Table 2105.86 (shown 

below) within one year from the Federal Register publication of final notice of conditional 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 44 
ACHD is confident that this commitment can be met for the following reasons. 

(1) The amount of technical 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 of the 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. 

Table 2105.86 

Monomer VOC Content Limitations 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 

Atomized (spray) 

Nonatomized 

Any Method 

Any Method 

Atomized 

Nonatomized 

Any Method 

Weight Average Monomer VOC Content Limit 

(weight percent) 

28 

35 

33 

48 

30 

39 

40 

ACHD understands that this commitment will result in a conditional approval by EPA of the 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 of the 

Pennsylvania SIP will become a full approval. 

This will be done promptly. 

cc: Ms. Joyce Epps, Pennsylvania DEP 

Ms. Irene Shandruk, U.S. EPA