RACT SIP SUBMITTAL 

As required for compliance with 

8-Hr Ozone NAAQS adopted July 18, 1997 

November 14, 2008 
ENCLOSURE I 

CERTIFICATION PURSUANT TO 40 CFR § 51 .102 

PUBLIC NOTICE OF SIP AMENDMENTS AND HEARING 

Enclosure 1 Page 1 
CERTIFICATION PURSUANT TO 40 CFR § 51 .102 

AND APPENDIX V OF 40 CFR PART 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 of 40 CFR § 

51 .102(a)-(d) were met. A public hearing concerning Vermont's proposed RACT SIP revisions 

was held on August 28, 2008 at 6 :00 pin in 104 Stanley Hall located on the grounds of the 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 of the 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 of the public hearing and a copy of the proposed RACT SIP revisions were 

also provided to EPA Region 1. Further, as required by Section 2.1(g) of Appendix V of 40 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 TO THE STATE IMPLEMENTATION PLAN 

FOR REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) 

UNDER THE 8-HR OZONE NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS) 

NOTICE OF PUBLIC HEARING 

The Vermont 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 of the 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 of these 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 of Vermont has 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 of the Clean Air Act (CAA). This means that the entire State is considered 

equivalent to a "moderate" ozone non-attainment area for purposes of requirements related to 

existing stationary sources of air pollutants . RACT VOC control is required on all existing 

specific source categories for which EPA has issued Control Techniques Guidelines (CTGs) and 

for all individual "major" stationary sources of either of the pollutants NOx and VOC. 

Exceeding the potential to emit 50 Tons/year of VOC or 100 Tons/year of NOx characterizes an 

existing stationary source as "major" . Attaining and maintaining concentrations of ground-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 CAA provisions 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 them and/or identified new RACT determinations for sources 

for which RACT had not been previously determined. The submittal will become a part of the 

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 pm in 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 form are requested to 

Enclosure 1 Page 3 
contact Doug Elliott by e-mail at dou .elliott La-),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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PROPOSED REVISION TO 

THE STATE IMPLEMENTATION PLAN FOR 

REASONABLY AVAILABLE 

CONTROL 

TECHNOLOGY (RACT) 

UNDER THE 8-HR 

OZONE NATIONAL 

AMBIENT AIR 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, hints but these con . 

now need to be reexamined and re-certified 

at D5 

RA CT for the 8-Hr ozone 

standard 

Although the State of 

Vermont has -,of rxper,-

1' 

enCed 3ctual Ylolatlpr" s 

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 

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Enclosure 1 Page 5