Sturm, Ruger & Company, Inc. 411 Sunapee Street Newport, NH. 03773 ] 

### ] ] ] FINAL RACT ORDER ISSUED October 13, 2003, Amended December 1, 2003



### -- - - - ----- - - - ] ARD-03-001 A. Introduction This RACT Order is issued by the New Hampshire Department ofEnvironmental Services, Air Resources Division, to Sturm, Ruger & Company, Inc., pursuant to RSA 125-C. 

### B. Parties
1. The New Hampshire Department ofEnvironmental Services, Air Resources Division ("DES"), is a duly constituted administrative agency ofthe State ofNew Hampshire having its principal offices at 29 Hazen Drive, Concord, NH 03302-0095 , telephone number (603) 271

- 1370

. 2. Sturm, Ruger & Company, Inc. ("Sturm, Ruger") is a New Hampshire corporation, having a mailing address of411 Sunapee Street, Newport, NH 03773, telephone number (603) 863-3300. C. Statements ofFact and Law 1. Sturm, Ruger is involved in the production of a variety of steel investment castings and the manu facture offirearms. Stunn, Ruger owns and opera tes the following processes at its Facilty located on 411 Sunapee Street in Newport, NH ("the Facility") :
a. W oodworking Spray Booths and Paint Mixing Room ; b. Solvent Metal Cleaning;
c. Powder Coating; d. Rustproofing;
e. Flash Dewax; f. Quality Assurance (Magnaflux); g. Heat Treat Quench; h. Wax Pattern Cleaning. 2. Effective August 19, 1995, DES re-adopted NH Code ofAdministrative Rules Env-A 1204 

### Stati onary Sources ofVolatile Organic Compounds (VOCs) with amendments. 3. Sturm, Ruger submitted a Reasonably Available Control Technology (RACT) compliance plan dated May 31, 1995 for the Facility, and subsequent ly submitted a request for anVOC RACT Order ARD-03-00 I Sturm, Ruger & Company, Inc -2-
extension for the RACT analysis for the Epoxy Enamel Spray Booth and Drying Oven dated February 27, 1997. 4. Sturm, Ruger submitted a RACT compliance plan for the Epoxy Enamel Spray Booth and Drying Oven dated March 27, 1997 as an amendment to the May 31, 1995 submittal. 5. On March 22, 2001 Sturm, Ruger, informed DES that it had conducted a voluntary envirorunental audit ofits air compliance program, pursuant to RSA 147-E The EnvironmentalAudit Statute. As a result ofthe audit, Sturm, Ruger identified two potential compliance issues:
a. The Flash Dewax process was not included in 1995 VOC RACT compliance plan since Sturm, Ruger, originally thought that process was exempt from VOC RACT pursuant to Env-A 1204.27(b)(4); and b

. Sturm, Ruger, was unable to completely convert the Epoxy Enamel Coating process to Powder Coating as originally anticipated in its 1995 VOC RACT compliance plan, due to quality control problems. 6. Sturm, Ruger, filed a revised VOC RACT compliance plan and permit application for the Epoxy Enamel Coating process, dated November 26,2001, classifying it as a minor core activity in accordance with Env-A 1204.02(d). 7. Sturm, Ruger, submitted an amended VOC RACT compliance plan, dated February 11, 2002, for the Flash Dewax process. 8. On February 11 , 2002 Sturm, Ruger submitted stack test results for Flash Dewax process demonstrating compliance with VOC RACT by meeting the presumptive norm of 81% control. The test was performed on November 20, 2001. 9. Sturm, Ruger submitted additional information for the Flash Dewax process which included capture efficiency determination, dated May 20, 2002. 10. In the letter dated July 12,2002 Sturm, Ruger submitted Supplemental VOC Emission Data!VOC Emissions Survey Results for a Flash Dewax process which included supporting information for destruction efficiency determination. Based on the stack test, the emissions from the Flash Dewax were determined to be less than 2 tons per year. 11. On September 25, 2002 Sturm, Ruger submitted revised emission estimates for Wax Pattern Cleaner based on vaporization/mass transfer model found in Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release and Inventory Form (EPA 1987). The emissions were determined to be less than one ton per year. 12. Sturm, Ruger, in a letter, dated November 5, 2002, informed DES that the Epoxy Enamel Coating process was completely replaced by a Powder Coating process . Sturm, Ruger also revised the emissions for the Heat Treat Quench and Solvent Metal Cleaning process. The emission estimates from these processes were reduced due to low vapor pressure ofquench oil and deduction ofemissions from the Solvent Metal Cleaning process that are shipped off site as waste.VOC RACT Order ARD-03-001 -3- Sturm, Ruger & Company, Inc 13. On May 5, 2003 DES received comments from EPA on the draft VOC RACT Order. As a result of EPA's comments the following revisions were implemented:
a. Sturm, Ruger accepted a limit of 1.0 lb VOC per gallon ofcoating for the powder coating operation which is stricter than what is required by Env.A 1204.15, Applicability Criteria and Compliance Standards for Coating of Miscellaneous Metal Parts andProducts; b. Sturm, Ruger agreed to restrict the use ofthe rustproofmg coa ting, ACA-RP-2, to the Building A Acid Cleaning Process only;
c. Minor core activity exemption was clarified in regards to quality assurance, heat treat quench and wax pattern cleaning; and d. Sturm, Ruger agreed to record the oven temperature for each unit, once per shift, prior to the first load being fed into an oven for the flash dewax process. 14. Sturm, Ruger, in submittals dated May 31, 1995, through May 8, 2003 proposed the following measures as RACT:
a. Woodworking Spray Booths and Paint Mixing Room Wood gunstock coating at the Facility involves the mixin g and application ofsolventbased stains, polyurethane topcoats, and thinners to wood substrates. Three paint spray booths are used to apply the coatings. The coatings are mixed and supplied from a centralized paint mixing room . Wood Gunstock Coating operations at the Facility are limited to the levels listed in Table 1 below in accordance with Env-A 1204.27 RACTEmission · Rates for Gunstock Coating and Env-A 1204.28(a)(3) VOC Content Limits for Spray Booth Cleaning Operations in Wood Furniture, Wood Burial Casket Finishing Operations and Gunstock Coating Processes:

Topcoat

Sealer Strippable Booth Coating Env-A 1204.27& Env-A 1204

.;28(a)(3) Limits.in lb VOC/lb solids, as applied, excluding water and exempt compounds (averaged over 24-hour period) · 2.0

2.3 0.8 1.1 Topcoat (30932) Fa cility does not use sealer 0.799 Aquavar (42541)VOC RACT Order ARD-03-00 I Sturm, Ruger & Company, Inc -4

-

Based on material safety data sheets ("MSDS") provided by Sturm, Ruger, the Facility is in compliance with the VOC RACT limits for polyurethane topcoat (30932) and Aquavar (42541)spray booth coatings. b. Solvent Metal Cleaning De greasing operations at the Facility consist ofa variety ofdifferent cold cleaning dip tanks located throughout the Facility. The degreasing medium used is Castrol Kleen 3400 Solvent, described on its MSDS as an aliphatic solvent naphtha( CAS #64742- 88-7). The degreasing units are used to clean various metal castings during assembly or finishing. The vapor pressure exerted by the Castrol Kleen 3400 Solvent at a temperature of 38° C has been calculated to be 5.0 mmHg. Based on this vapor pressure, the requirements ofEnv-A 1204.44(a) through (b)(l) and (2) Compliance Standards for Cold Cleaning are not applicable to these units. However, the labeling and operating requirements found in Env-A 1204.44(b)(3) and Env-A 1204.44(c) are applicable to the degreasing units because these requirements are not vapor pressure dependent. Sturm, Ruger shall comply with the applicable labeling and operating requirements as stated above

. c. Powder Coating The powder coating booths do not vent during application. Instead, the over-spray powder is collected and returned to the reservoir. The·only VOC emissions from powder coating ("Tiger"-Drylac) occur in the drying oven. At that time, any residual VOC in the powder is released. Based on the powder coating' s MSDS, the coating contains a maximum of 1% VOC by weight or 0.1 pounds ofVOC per gallon of coating. The Facility is subject to Env

-A 1204.15(c)( 4) requiring a limit of 3.0 pounds ofVOC per gallon ofcoating. Therefore, the "Tiger"-Drylac coating is VOC RACT compliant. d. Rustproofing The rust preventive process at the Facility involves dipping baskets ofmetal parts in an oily hydrocarbon mixture prior to the temporary storage ofthe parts before their integration into the production process. This process is subject to Env-A 1204.15( c)(2) which limits emissions to 3.5 pounds ofVOC per gallon ofcoating, less water and exempt compounds. Some ofthe materials used in the rustproofmg process meet the applicable VOC RACT requirements (ACA Protect BAC-2.0 lb VOC/gallon coating and Rust Veto 4242-3.36lb VOC/gallon coating). However, the rustproofmg that takes place in the Building A, acid cleaning room, uses a non-compliant coating ACA-RP-2, CAS# 64742-48-9, (6.34lb VOC/gallon coating). The rustproofing perfonned in this area is different from other rustproofmg operations at the Facility because the parts coated here are shipped for sale instead ofVOC RAC T Order ARD-03-001 -5

- Stunn, Ruger & Company, Inc being used in the Facility's production lines. The coatings used on these parts must endure much longer storage times and harsher environmental conditions prior to use ofthe parts
. Therefore, the coatings used are low-emitting by design since a more volatile ingredient would not remain on the parts long enough to inhibit rust formation. Sturm, Ruger believes that due to the low volatility ofACA-RP

-2 (vapor pressure less than 10 mmHg) the majority ofliquid losses leave the dip tanks as coating on cast parts rather than emissions to the atmosphere. The majority ofliquid losses occur at Sturm, Ruger's customers where the rustproofing coating is removed by degreasing before it enters their production stream. Sturm, Ruger believes that, due to the low emissions based on low vapor pressure, add-on controls are economically infeasible. The Facility therefore claims that current operations are RACT

. The DES has determined that, based on the low volatility ofACA-RP-2 and the feasibility study for implementing the available control technologies, submitted on June 1, 1995, the current operations are RACT.
e. Flash Dewax The flash dewax process consists ofrapidly heating the molds in an oven to melt the wax and drain it from the molds. Sturm, Ruger operates three flash dewax furnaces which melt the wax, causing it to drain from the mold. The Flash Dewax process is subject to Env-A 1204.48, Applicability Criteria for Miscellaneous and Multicategory Stationary VOC Sources. Sturm, Ruger chose to comply with VOC RACT by meeting the presumptive norm of 81% control. Based on stack testing performed onNovember 20, 2001 and the VOC destruction rate of98% achieved as a result ofoven combustion, the flash dewax process exceeds the presumptive norm requirement. Therefore, the current process is RACT. f. Minor Core Activities Pursuant to Env-A 1204.02(d), minor core activities ofVOCs a t a stationary source, having total aggregate emissions ofnot more than 5 tons per year combined for all classifiable and unclassifiable processes or devices, are exempt from VOC RACT requirements established in Env-A 1204. The following core activities, Quality Assurance, Heat Treat Quench, and Wax Pattern Cleaning have been determined to meet the definition ofminor core activity (see Env

-A 1204.03(bi)) and , therefore are exempt from the provisions ofEnv-A 1204.



### D. Order Based on the above findings and determinations, DES hereby orders Sturm, Ruger to implement the following requirements as RAC T:VOC RACT Order ARD-03-00 l Sturm, Ruger & Company, Inc 1. Emission Rates for GW1stock Coating -6-

a. In accordance with the provisions ofEnv-A 1204.27 and Env-A 1204.28(a)(3) emissions from Woodworking Spray Booths and Paint Mixing Room shall be limited, at all times, to rates specified in Table 2 below: Tabl e 2

-- Type of Coating lb VOC/lb solids, as applied, excluding water and ' exempt compounds (averaged over 24-hour period) Topcoats 2.0

Sealers 2.3 St

rippa ble Booth Coatings 0.8
b

. In accordance with the provisions ofEnv

-A 1204

.28(b) the VOC emissions associated with material storage or solvent cleaning operations shall be controlled as follows;
1. All finishing and cleaning materials shall be stored in a normally closed container;
11. All organic solvents used for line cleaning shall be pumped or drained into a normally closed container;
m. All organic solvent used to clean spray gW1S shall be collected into a normally closed container; and tv. Emissions from washoffoperations shall be controlled by: ( 1) Using normally closed tanks for washoff; and (2) Minimizing dripping by tilting or rotating the part to drain as much organic solvent as possible.
c. In accordance with Env-A 1204.29 Control Techniques for W ood Furniture, Wood Burial Casket, and Gunstock Coating Facilities, for all gm1stock coating operations at the facility, one or more ofthe following control techniques shall be used:
1. High volume-low pressure (HVLP) spray;
n . Airless spray;
m. Air-assisted airless spray;
IV. Flow coating techniques; or
v. Conventiona l air spray W1der any one or more ofthe following circumstances: (1) The application offinishing materials having a VOC content not greater than 1.0 lb VOC/lb solids, as applied; (2) The spray is automated;VOC RACT Order ARD-03-00 I -7

- Sturm, Ruger & Company, Inc (3) The emissions from the finishing application station are directed to add-on control equipment; (4) The conventional air spray gun is used to apply finishing materials and the cumulative total usage ofthat finishing material is less than 5% ofthe total gallons offinishing material used during the applicable semi-annual period; (5) The conventional air gun is used to apply stain on a part for which it is technically or economically infeasible to use any other spray application technology, as demonstrated in accordance with the provisions of(vi) below; or (6) Touch-up and repair activities in accordance with the provisions ofEnv-A 1204.30 Compliance Standards for Touch-Up andRepairActivities at Wood Furniture, Wood Burial Casket, and Gunstock Coating Facilities. vt. Any source intending to use conventional air spray pursuant to the paragraph c.v.(5) above, shall demonstrate technical oreconomic infeasibility according to the requirements in Env-A 1204.29(c). d. In accordance with Env-A 1204.30, touch-up and repair activities, excluding such activities that employ only compliant coating materials and one or more ofthe application techniques listed in Section D.1.c., above, shall conform to the following requirements:
1. Touch-up and repair activities using conventional air spray shall comply with one or more ofthe following requirements: (1) The touch-up and repair finishing materials shall be applied after the completion ofthe finishing operation; or (2) The touch-up and repair finishing materials shall be : (a) Applied after the application ofthe stain and prior to the application of any other types offinishing material; and (b) Applied from a container with a capacity ofnot more than 2 gallons; (3) Total VOC consumption associated with touch-up and repair activities using conventional air spray shall not exceed 5 gallons per day at a stationary source; and
11. Consumption oftouch-up and repair finishing materials shall not exceed I0 gallons per day where such activities employ: (1) The use ofaerosol containers; or (2) One or more non-compliant coating materials in conjunction with any of the application techniques listed in Section D.1.c. above.VOC RACf Order ARD-03-001 Sturm, Ruger & Company, Inc 2. Compliance Standards for Cold Cleaning -8-

In accordance with the provisions ofEnv-A 1204.44(b)(3) and Env-A 1204.44(c) Sturm, Ruger shall comply with the labeling and operating requirements for cold cleaning processes which require a permanent, legible, conspicuous label, affixed to each solvent container, summarizing the operating requirement s as follows:
a. Waste solvent shall be stored only in covered containers; b. The degreaser cover shall be closed whenever parts in the cleaner are not being handled manually;
c. Cleaned parts shall be drained for at least 15 seconds or until dripping ceases, whichever is longer; d. Solvent leaks shall be repaired immediately or the degreaser shall be shut down;
e. Drafts across the top ofeach cold cleaning unit shall be minimized ; f. Where a so lvent spray is used, such spraying shall be:
1. Operated at a pressure which does not exceed 10 pounds per square inch as measured at the pump outlet; and
n. Performed only within the confmes ofthe degreasing unit. 3. Applicability Criteria and Compliance Standards for Coating ofMiscellaneous Metal Parts and Products
a. Sturm, Ruger agreed to limit the VOC emission rate from all metal parts coating operation, other than rustproofing activities, at all times, to 1.0 lbs ofVOC per gallon ofcoating, as applied, excluding water and exempt compounds . b. In accordance with the provisions ofEnv-A 1204.15(c)(2) the VOC emission rate from the Rustproofing operation, shall be limited, at all times, to 3

.5 lbs ofVOC per gallon ofcoating, as applied, excluding water and exempt compounds for all coatings except ACA-RP-2 with 6.34lbVOC/gal coating.
c. Use ofthe ACA-RP-2 product shall be restricted to the Building A Acid Cleaning Process only. Th e product, ACA-RP-2, may be substituted with another product of equal or lesser VOC content. 4. Applicability Cr iteria for Miscellaneous and Multicategorv Stationary VOC Sources
a. For Flash Dewax process: 1. In accordance with the provisions ofEnv-A 1204.48(d) Sturm, Ruger shall comply with VOC RACT by meeting the presumptive norm of 81% control.
n. Sturm, Ruger shall operate each flash dewax furnace at a minimum temperature set point of 1,000° F when molds are 

### in the furnace.VOC RACT Order ARD-03-00 1 Stunn, Ruger & Company, Inc -9-

111. Each thermocouple and temperature controller shall be calibrated quarterly according to manufacturer's specifications in order to maintain nominal oven temperature of 1,000°F 1

. 5. Minor Core Activities Pursuant to Env-A 1204.02(d), minor core activities are exempt from the VOC RACT requirements ofEnv

-A 1204. VOC emissions from all minor core activities shall be limited to 5 tons combined in any consecutive 12-month period. Minor core activities currently include: Quality Assurance, Heat Treat Quench and Wax Pattern Cleaning. Ifat any time, the VOC emissions from above processes exceed 5-ton limit, the process(es) exceeding the limit become subject to the provisions ofEnv-A 1204.48 for unclassifiable processes. 6. Monitoring
a. The owner or operator ofa solvent metal cold cleaner, shall use visual inspection for compliance with equipment specifications and operating procedures. b. For the Flash Dewax Oven the operator shall:
1. Maintain the ovens at a minimum temperature set point of 1,000°F while molds are in the ovens; 11. Each thermocouple and temperature controller shall be calibrated quarterly according to manufacturer's specifications in order to maintain nominal oven temperature of 1,000°F;
m. Record the oven temperature for reach 

### unit, once per shift, prior to the first load being fed into an oven; tv. Readings before and after adjustment should be recorded; ifno adjustments are necessary, that should also be recorded;
v. All records should include identification ofthe instrument componen t calibrated, the date ofcalibration, and the initials ofthe person who performed the calibration. 7. Recordkeeping and Reporting
a. For the processes listed in D.1. through D.4. the Facility shall:
1. Record the monthly raw material usage from each operat ion; 11. Record the monthly VOC emissions from each operation; and
111. Report this information to DES annually by April 15th for each preceding calendar year. iv. Maintain records of the calibration and temperature read ings for flash de wax
1 DES understand that the flash dewax ovens operate wit h temperature set point that equal s 1 ,000°F when parts a re in the furnace. This results in oven temperatures that are typically near 1 ,000°F, however there are times during normal operation when the oven temperature goes below 1 ,000°F.VOC RACT Order ARD-03-00 1 Sturm, Ruger & Company, Inc ovens on site for inspection. - 10-

v . Maintain product formulations furnished by the material supplier documenting the lbs VOC/gallon ofmaterial, as applied, excluding water and exempt compounds; and v1. Prior to the use ofany new coatings, Sturm, Ruger shall demonstrate compliance with processes listed in D.l. and D.3. 1as applicable, by one ofthe following options: (1) Prima facie evidence which allows the use ofchemical manufacturers' MSDS information (density and weight percent VOC content) along with the Facility coating formulation recipe information (gallons ofeach ingredient, i.e. resins, cure, diluent solvent, and exempt diluent solvent; density ofeach ingredient; and weight percent VOC content ofeach ingredient). The Facility shall calculate the pounds ofVOC per gallon ofcoating minus water and exempt compounds for the coating as applied via use ofthe following formula: P*X 

### (1- Yw- Ye) Where: P=Density ofthe mixed coating as applied (pounds coating/gallon coating) X= Weight fraction ofVOC in the mixed coating Yw= Volume fraction ofwater in the mixed coating Ye= Volume fraction ofexempt compounds in the mixed coating When using prima facie evidence as obtained in the above fashion, the Facility shall maintain the calculation sheets and records for each coating formulation. All Method 24 analyses and prima facie evidence calculation sheets for new coatings shall be submitted in the annual VOC report; OR (2) For sources subject to Env-A 1204, when formal compliance is demonstrated for the low VOC coatings, the referee liquid VOC test method for ultimate determination ofcompliance with VOC RACT shall be the EPA reference methods specified as follows: (a) Method 24, 40 CFR part 60, Appendix A for all coatings as applicable using the 60

-minute bake time procedure; or (b) Method 24A, 40 CFR Part 60, Appendix A as applicable. b. The owner or operator shall record the annual VOC emissions from the minor core activities.VOC RACT Order ARD-03-001 Sturm, Ruger & Company, Inc Please address any correspondence and communication in ref erence to this Order to: Ms. Danuta Lempert NHDES, Air Resources Division 29 Hazen Drive, P.O. Box 95**Concord ~**  033 02-0095 (603) 271-2822

cc: Timothy Drew, NHDES , PIP Office David Conroy, U S EPA Town Selectmen Robert R

. Scott Director Air Resources Division

H:\PERMITS\CURRENT\Sullivan 19\Stunn\VOC RACT Order\Sturm RO fa 12

- 1-03

.doc - II
-