Commonwealth of Massachusetts 

Executive Office of Energy & Environmental Affairs 

Department of Environmental Protection 

One Winter Street Boston, MA 02108•617-292-5500 

Charles D. Baker 

Governor 

Matthew A. Beaton 

Secretary 

Karyn E. Polito 

Lieutenant Governor 

July 15, 2015 

David Conroy 

Chief, Air Programs Branch 

EPA Region I 

5 Post Office Square Suite 1 00 

Boston, MA 021 09-3912 

Re: Withdrawal of Portion of July 10, 2014 SIP Revision 

Dear Mr. Conroy: 

On July 10. 2014 the Massachusetts Department of Environmental Protection (MassDEP) 

submitted a revision to the State Implementation Plan (SIP) adding amendments to 310 CMR 

7.18 regulating adhesives and sealants. By this letter MassDEP hereby withdraws31 0 CMR 

7.18(1)(b) from that submittal since this portion of the regulation is not needed in the SIP. 

Martin Suuberg 

Commissioner 

The withdrawn provision is indicated with strikethrough in the attached revised page of the final 

regulations that we originally submitted. 

If you have any questions, please contact Glenn Keith of my staff at 617-292-5874. 

Sincerely, 

") 

/ 

c_:.:~ 

Christine Kirby, Director 

Division of Air & Climate Programs 

Bureau of Air and Waste 

cc: Anne Arnold, EPA Region 1 

This information is available in alternate format. Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 

MassDEP Website: www.mass.gov/dep 

Printed on Recycled Paper 
FINAL REGULATIONS 8/30/2013 

1

[Amend 310 CMR 7.18 (1), 7.18(2)(a), 7.18(2)(b), and 7.18(2)(f) as follows.] 

310 CMR 7.18 

(1) U Applicability and Handling Requirements. 

(a) 310 CMR 7.18 shall apply in its entirety to persons who own, lease, operate or control any 

facility which emits volatile organic compounds (VOC). 

 (b) For purposes of 310 CMR 7.18, except for 310 CMR 7.18(30), VOC shall include both VOC 

as defined in 310 CMR 7.00 and Halogenated Organic Compounds (HOC) as defined in 310 CMR 

7.00. 

(c) On or after July 1, 1980 any person owning, leasing, operating, or controlling a facility 

regulated under 310 CMR 7.18, shall store and dispose of volatile organic compounds in a manner 

which will minimize evaporation to the atmosphere. Proper storage shall be in a container with a 

tight fitting cover. Proper disposal shall include incineration in an incinerator approved by the 

Department, transfer to another person licensed by the Department to handle VOC, or any other 

equivalent method approved by the Department. 

(d) Any person who owns, leases, operates, or controls a facility which is or becomes subject to 

310 CMR 7.18, except for those persons solely subject to 310 CMR 7.18(30) unless the facility is a 

CTG-affected facility as defined under 310 CMR 7.18(30)(b), Definitions, shall continue to comply 

with all requirements of 310 CMR 7.18, even if emissions from the subject facility no longer exceed 

applicability requirements of 310 CMR 7.18. 

(e) Any person not regulated by 310 CMR 7.18, prior to August 15, 1989 shall achieve 

compliance with the applicable section(s) of 310 CMR 7.18 by August 15, 1990. 

(f) Any person who, since January 1, 1990, obtains a plan approval for an emission unit under 

310 CMR 7.02 where said approval establishes BACT or LAER to be no less stringent than RACT 

for a facility size and type as defined in 310 CMR 7.18, shall comply with the BACT or LAER as 

defined established in the plan approval, and is not subject to RACT standards of 310 CMR 7.18

this section as may otherwise be applicable, until the applicable RACT standards of 310 CMR 7.18 

become more stringent than the BACT or LAER established in the plan approval, at which point the 

person shall become subject to the updated RACT standards.

(2) U Compliance with Emission Limitations. 

(a) Any person subject to 310 CMR 7.18 shall maintain continuous compliance with all 

requirements of 310 CMR 7.18. Except as provided for in 310 CMR 7.18(2)(b) and (g), compliance 

averaging times are based on the control method selected to meet the applicable emission 

limitations and EPA test methods as codified in 40 CFR Part 60, or other methods approved by the 

Department and EPA, and are as follows: 

 

Compliance Method EPA Reference Test Method Test Method Averaging Time 

Coating Reformulation 24

1 

instantaneous 

Solvent destruction or solvent 25 3hours 

recovery except carbon 

adsorption 

Carbon adsorption 25 or other as appropriate the length on the adsorption 

 cycle or 24-hours, whichever is 

 less. 

 

1 

Reference Method 24 shall use a 60 minute bake time at 110°C ± 5°C. 

(b) Persons owning, leasing, or controlling the operation at a specific site location of any 

individual or combination of coating lines described in 310 CMR 7.18(3) through (7), (10) through 

(12), (14) through (16), and (21) through (24) may, for compliance with dates specified in 310 

CMR 7.18(3)(2)(a), through (7), (10) through (12), (14), (15), through (16), and (21) through (24),

and the emissions limitations contained in 310 CMR 7.18(3) through (7), (10) through (12), (14) 

through (16), and (21) through (24), submit a proposed plan containing a mix of emission limits for 

such coating lines such that the total emissions from all coating lines is less than or equal to the sum