# RACT SIP SUBMITTAL
As required for compliance with 8-Hr Ozone NAAQS adopted July 18, 1997

November 14, 2008

# ENCLOSURE I
CERTIFICATION PURSUANT TO40 CFR§ 51 .102 PUBLIC NOTICE OF SIPAMENDMENTS ANDHEARING

Enclosure 1 Page 1

# CERTIFICATION PURSUANT TO40 CFR§ 51 .102 ANDAPPENDIXVOF 40 CFRPART 51

REGARDING Vermont Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revisions Required for the 1997 8-Hour Ozone National Ambient Air Quality Standard
As required by 40 CFR § 51 .102(f), I hereby certify that the requirements of40 CFR§ 51 .102(a)-(d) were met
. Apublic hearing concerning Vermont's proposed RACT SIP revisions was held on August 28, 2008 at 6:00pin in 104 Stanley Hall located on the grounds ofthe State Office Complex at 103 South Main Street, Waterbury, Vermont
. Public notice for this hearing was published on July 24, 2008 in the following newspapers: Burlington Free Press, Rutland Herald, Caledonian Record, Times Argus, and Vermont Lawyer
. Said notice specified the date, time, and place ofthe public hearing on Vermont's proposed RACT SIP revisions and also specified the locations at which the proposed RACT SIP revisions would be available for public inspection
. Notice ofthe public hearing and a copy ofthe proposed RACT SIP revisions were also provided to EPARegion 1
. Further, as required by Section 2 .1(g) of Appendix Vof40 CFR Part 51, I hereby certify that the public hearing was held in accordance with the information provided in the public notice and the State's laws and constitution, as applicable, and consistent with the public hearing requirements in 40 CFR§ 51 .102
.

Richard A

. Valentinetti Certifying Officer

Enclosure 1 Page 2

# PROPOSED REVISION TOTHE STATE IMPLEMENTATION PLAN FOR REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) UNDERTHE 8-HR OZONE NATIONAL AMBIENTAIRQUALITY STANDARD (NAAQS) NOTICE OF PUBLIC HEARING

TheVermont Department of Environmental Conservation, Air Pollution Control Division plans to submit to the U.S
. Environmental Protection Agency (EPA), a proposed revision to the Vermont State Implementation Plan (SIP) for Air Quality
. The purpose ofthe submittal is to respond to a deficiency in the Vermont SIP related to certification that all relevant existing stationary emission sources of the criteria pollutants oxides of nitrogen (NOx) and volatile organic compounds (VOC) are applying reasonably available control technology (RACT) as part of regional strategies to achieve the federal 8-Hr ozone standard (NAAQS) adopted in 1997
. The applicable existing Vermont sources ofthese criteria pollutants were required to achieve RACT control levels related to the previous 1-Hr ozone standard, but these controls now need to be reexamined and re-certified as representative of RACT for the 8-Hr ozone standard
. Although the State ofVermonthas not experienced actual violations of the federal 8-Hr ozone standard, Vermont is included as part of the Ozone Transport Region (OTR) established under Section 184 ofthe Clean Air Act (CAA)
. This means that the entire State is considered equivalent to a "moderate" ozone non-attainment area forpurposes of requirements related to existing stationary sources ofair pollutants
. RACT VOCcontrol is required on all existing specific source categories for which EPAhas issued Control Techniques Guidelines (CTGs) and for all individual "major" stationary sources of either ofthe pollutants NOx and VOC
. Exceeding the potential to emit 50 Tons/year ofVOCor 100Tons/year of NOx characterizes an existing stationary source as "major"
. Attaining and maintaining concentrations ofground-level ozone below

the health-based NAAQS is important because ozone is a serious human health threat, and also because it can cause damage to important food crops, forests, and wildlife
. The Division is certifying through this RACT SIP revision that all stationary sources in Vermont on which RACT is required under the CAAprovisions as they relate to the 8-Hr ozone NAAQS are complying with this requirement
. The Division has re-examined all previous RACT determinations and has certified themand/or identified new RACT determinations for sources for which RACT had not been previously determined
. The submittal will become a part ofthe federally enforceable Vermont SIP once it has been approved by EPA
. The Division is seeking public comment on this proposed SIP revision
. The entire proposed submittal package is available electronically on the Air Pollution Control Division web page located at http: ://www

.anr.state.vt.us/air/ , or it may be inspected at the Division offices located in Building 2 South, 103 South Main Street, Waterbury, Vermont 05671-0402
. The Division will hold a public hearing on this proposed RACT SIP revision on Thursday August 28, 2008 at 6:00 pmin 104 Stanley Hall which is located on the grounds of the State Office Complex at 103 South Main Street, Waterbury, Vermont
. Persons wishing to attend the hearing and/or offer testimony on this proposal in either written or oral formare requested to
Enclosure 1 Page 3

# contact Doug Elliott by e-mail at dou .elliottLa-),state.vt.us or by telephone at 802-241-3845 if

possible
. There is no requirement to contact us prior to the hearing however, as it will be held at the stated time and place

. Comments on the proposed RACT SIP will be accepted until the close of business on Friday August 29, 2008
.

Enclosure 1 Page 4

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_/71 PROPOSED REVISION TO

THE STATE IMPLEMENTATIONPLAN FOR REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) UNDERTHE8-HR OZONE NATIONAL AMBIENTAIR QUALITY STANDARD(NAAQS) NOTICE OF PUBLIC HEARING The Vermont Department of Envlronmental Conservation, Air Pollu " tlon Control Division plans to submit to the U.S Envlronmental Protectlon Agency IEPA), a proposed revision to the Vermont State Implemertatnon Plan SIP) for Air quality
. The purpose of th e submittal is to respond to a deficiency in the Vermont SIP related to cernflcabon that all relevant existing stanonary emlsslon sources a the criteria onilutants oxides of nitrogen (NOx) ana volatile organic compounds (V C) are appfyIng reasonably available control technology (RACT) as part at regionat strategies to achieve the federal B-Hr ozone standard INAAQS) adopted m 1997 The ~ applicable existing Vermont sources of these cnterla pollutants were reqmred to achieve RACT control levels related to the previous ' .hr ozone standard, but these con . hints now need to be reexamined and re-certified at D5CT RA for the 8-Hr ozone standard Although the State of Vermont has -,of rxper,- enCed 3ctual Ylolatlpr" s 1' ul the federal B-Hr ozone slandalo, Vermont is included as part of the Ozone Transport Region (OTR) established under Section 184 of the Clean Au Act (CAA)
. This means that the entire' Stale is considered equlvalent to a 'moderate" ozone non-attainment area far purposes of reqmrements roiated to elnsbng stauonary sources of air pollutants
. RACT VOC ~" onirol ~s quired on all existing specific source catego~ rles for which EPA has issued Control Techniques Guidelines (CTGs) and for all Indmdual 'major- stahonary sources of either of the pollutants NOx and VOC Exceeding [he potential to emit 50 Ton /yea, ol VOC or 100 fons " year ot NOx char actenzes an ensung stai nonary ,ource as malor Tf

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# Enclosure 1 Page 5