Sturm, Ruger & Company, Inc. 

411 Sunapee Street 

Newport, NH. 03773 

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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 of Environmental Services, Air 

Resources Division, to Sturm, Ruger & Company, Inc., pursuant to RSA 125-C. 

B. Parties 

1. The New Hampshire Department of Environmental Services, Air Resources Division 

("DES"), is a duly constituted administrative agency of the 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 of 411 Sunapee Street, Newport, NH 03773, telephone number (603) 

863-3300. 

C. Statements of Fact and Law 

1. Sturm, Ruger is involved in the production of a variety of steel investment castings and the 

manufacture of firearms. Stunn, Ruger owns and operates the following processes at its 

Facilty located on 411 Sunapee Street in Newport, NH ("the Facility"): 

a. Woodworking 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 of Administrative Rules Env-A 1204 

Stationary Sources of Volatile 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 subsequently submitted a request for an 
VOC RACT Order ARD-03-00 I 

Sturm, Ruger & Company, Inc 

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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 of its air compliance program, pursuant to RSA 147-E The 

Environmental Audit Statute. As a result of the 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 of quench 

oil and deduction of emissions from the Solvent Metal Cleaning process that are shipped 

off site as waste. 
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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 of coating 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 and Products; 

b. Sturm, Ruger agreed to restrict the use of the rustproofmg coating, 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 mixing and application of solventbased 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 RACT Emission· 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) 

Facility does not use sealer 

0.799 

Aquavar (42541) 
VOC RACT Order ARD-03-00 I 

Sturm, Ruger & Company, Inc 

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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 of a variety of different 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 of coating. Therefore, the "Tiger"-Drylac coating is VOC 

RACT compliant. 

d. Rustproofing 

The rust preventive process at the Facility involves dipping baskets of metal parts in 

an oily hydrocarbon mixture prior to the temporary storage of the 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 of V OC per gallon of coating, 

less water and exempt compounds. Some of the 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 of 
VOC RACT 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 

of the 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 of ACA-RP-2 (vapor pressure less 

than 1 0 mmHg) the majority of liquid losses leave the dip tanks as coating on cast 

parts rather than emissions to the atmosphere. The majority of liquid 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 of ACA-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 of rapidly 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 on November 20, 2001 and the VOC destruction 

rate of98% achieved as a result of oven 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 at a stationary source, 

having total aggregate emissions of not 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 of minor 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 RACT: 
VOC RACT Order ARD-03-00 l 

Sturm, Ruger & Company, Inc 

1. Emission Rates for GW1stock Coating 

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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: 

Table 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 

Strippable 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 washoff operations 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 Wood Furniture, Wood 

Burial Casket, and Gunstock Coating Facilities, for all gm1stock coating operations at 

the facility, one or more of the 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. Conventional air spray W1der any one or more of the following circumstances: 

(1) The application of finishing 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 of that finishing material is less than 5% of the total 

gallons of finishing 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 and Repair Activities 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 or economic 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 of the 

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 of the following requirements: 

(1) The touch-up and repair finishing materials shall be applied after the 

completion of the finishing operation; or 

(2) The touch-up and repair finishing materials shall be: 

(a) Applied after the application of the stain and prior to the application 

of any other types of finishing material; and 

(b) Applied from a container with a capacity of not 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 of touch-up and repair finishing materials shall not exceed I 0 

gallons per day where such activities employ: 

(1) The use of aerosol 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 

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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 requirements 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 of each cold cleaning unit shall be minimized; 

f. Where a solvent 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 of the degreasing unit. 

3. Applicability Criteria and Compliance Standards for Coating of Miscellaneous 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 of VOC per gallon 

of coating, 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 of coating, as applied, excluding water and exempt compounds for all coatings 

except ACA-RP-2 with 6.34lbVOC/gal coating. 

c. Use of the ACA-RP-2 product shall be restricted to the Building A Acid Cleaning 

Process only. The product, ACA-RP-2, may be substituted with another product of 

equal or lesser VOC content. 

4. Applicability Criteria 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 

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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°F1. 

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. If at 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 of a 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; if no adjustments are 

necessary, that should also be recorded; 

v. All records should include identification of the instrument component 

calibrated, the date of calibration, and the initials of the 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 operation; 

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 readings for flash de wax 

1 DES understand that the flash dewax ovens operate with temperature set point that equals 1 ,000°F when parts are 

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. 

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v. Maintain product formulations furnished by the material supplier documenting 

the lbs VOC/gallon of material, as applied, excluding water and exempt 

compounds; and 

v1. Prior to the use of any new coatings, Sturm, Ruger shall demonstrate 

compliance with processes listed in D.l. and D.3. 1

as applicable, by one of the 

following options: 

(1) Prima facie evidence which allows the use of chemical manufacturers' 

MSDS information (density and weight percent VOC content) along 

with the Facility coating formulation recipe information (gallons of each 

ingredient, i.e. resins, cure, diluent solvent, and exempt diluent solvent; 

density of each ingredient; and weight percent VOC content of each 

ingredient). The Facility shall calculate the pounds ofVOC per gallon 

of coating minus water and exempt compounds for the coating as applied 

via use of the following formula: 

P*X 

(1- Yw- Ye) 

Where: 

P=Density of the mixed coating as applied (pounds coating/gallon coating) 

X= Weight fraction ofVOC in the mixed coating 

Yw= Volume fraction of water in the mixed coating 

Y e= Volume fraction of exempt 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 of compliance 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 reference to this Order to: 

Ms. Danuta Lempert 

NHDES, Air Resources Division 

29 Hazen Drive, P.O. Box 95 

Concord ~ 03302-0095 

(603) 271-2822 

cc: Timothy Drew, NHDES, PIP Office 

David Conroy, US 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 

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