Sturm, Ruger & Company, Inc. 

411 Sunapee Street 

Newport, NH. 03773 

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Final RACT ORDER 

October 13, 2003, Amended 

December 1, 2003, Amended ___________________________ ] March 2, 2010, Amended March 21,2012 

ARD-03-001 

A. Introduction 

This RACT Order is issued by the New Hampshire Department of Envirorunental 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 of New 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 

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

manufacture of firearms. Sturm, 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; and 

h. Wax Pattern Cleaning. 

2. Effective August 19, 1995, DES re-adopted NH Code of Administrative Rules Env-A 204 

Stationary Sources of Volatile Organic Compounds (VOCs), with amendments. 

3. Sturm, Ruger submitted a Re~sonably Available Control Technology (RACT) compliance 

plan dated May 31 , 1995 for the Facility, and subsequently submitted a request for an 

extension for the RACT analysis for the Epoxy Enamel Spray Booth and Drying Oven dated 

February 27, 1997. 
VOC RACT Order ARD-03-00 I 

Sturm, Ruger & Company, Inc 

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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 

environmental 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. ln 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 the deduction of emissions from waste from the Solvent Metal Cleaning process which is 

shipped off site for disposal. 

13. Effective December 31, 2002, DES readopted Env~A 1204, with amendments. 
VOC RACT Order ARD-03-00 I 

Sturm, Ruger & Company, Inc 

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14. 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 12'04.15, Applicability 

Criteria and Compliance Standards for Coating of Miscellaneous Metal Parts and 

Products; 

b. Sturm, Ruger agreed to restrict the use of the rustproofing coating, ACA-RP 2~ to the 

Building A Acid Cleaning Process only; 

c. The minor core activity exemption was clarified in regards to quality assurance, heat 

treat quench and wax I?attern 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. 

15. 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 thi1mers 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 

Sturm, Ruger's Emission 

Rates in lb"VOC/Ib solids ... 

1.1 

Topcoat (30932) 

Facility does not use sealer 

0.799 

Aquavar ( 42541) 

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 

VOC RACT Order ARD-03-00 I 

Sturm, Ruger & Company, Inc 

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Degreasing operations at the Facility consist of a variety of different cold cleaning dip 

tanks located throughout the Facility. The degreasing medium used is Castro! 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 Castro! Kleen 3400 Solvent at a temperature of 3 go C 

has been calculated to be 5.0 mmHg. Based on this vapor pressure, the requirements of 

Env-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 l204.44(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 of VOC per gallon of coating. The 

Facility is subject to Env-A 1204.15(c)(4), requiring a limit of3.0 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 VOC per gallon of coating, less water and 

exempt compounds. Some ofthe materials used in the rustproofing 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 rustproofing that takes place in the Building A, acid cleaning room, uses a 

non-compliant coating ACA-RP-2, CAS# 64742-48-9, (6.34 lb VOC/gallon coating). 

The rustproofmg performed in this area is different from other rustproofing operations at 

the Facility, because the parts coated here are shipped for sale instead of 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 
VOC RACT Order ARD-03-001 -5 -

Sturm, Ruger & Company, Inc 

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. 

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. 

16. On November 19, 2009, Sturm, Ruger submitted an application for a Temporary Permit for a 

proposed Camouflage Image Transfer and Coating Process Line and a new Stainless Steel 

Bluing Line. 

17. On December 21, 2009, Sturm, Ruger submitted a V OC RA CT plan for the proposed 

processes covered under the November 19, 2009 permit application. The submittal included 

the following proposed RACT limits: 

a. Bluing Line - Rust Preventative 

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 ofVOC per gallon of coating, less water and 

exempt compounds. 
VOC RACT Order ARD-03-001 - 6 -

Sturm, Ruger & Company, Inc 

The new bluing line will require a rustproofing step similar to the existing operation 

conducted in Building A. The rustproofing coating that will be used (Pen Dip Super) is 

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 Pen Dip Super (vapor pressure 

less than 1 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 occm 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 proposed operation is RACT. 

DES has determined that, based on the low volatility of Pen Dip Super and the feasibility 

study for implementing the available control technologies, submitted by Sturm, Ruger on 

December 21, 2009, the proposed operation is RACT. 

b. Camouflage Image Transfer and Coating Process 

The proposed camouflage coating process will consist of a primer booth to apply an 

adhesion primer to a metal or plastic substrate, an image transfer process, known as 

water transfer printing, and a topcoat booth to apply a gloss-reducing clear topcoat to 

permanently seal and protect the camouflage image. 

The coatings proposed for use in both the primer and topcoat booths meet the established 

VOC content limitations under Env-A 1204.15 and Env-A 1204.22, General 

Compliance Standards for Plastic Parts Coating. 

The water transfer printing process is not a coating process, as it involves the transfer of 

a previously printed, discrete image onto the desired substrate. A solvent-based 

activator/release agent is used to prepare the image for transfer. No specific VOC 

limitation exists for this type of process and, therefore, it.is classified as an unclassified, 

miscellaneous process under Env-A 1204.49, Compliance Options for Miscellaneous 

and Multicategory Stationary VOC Sources. The activator/release agent has a VOC 

content of 6.89 lb VOC/gal of solution. In its submittal dated December 21, 2009, 

Sturm, Ruger estimated that emissions from this process would be approximately 0.05 

pound ofVOC per gun produced. A paint-based camouflage coating process, using a 

coating with a VOC content of3.5 lb VOC/gal coating, is estimated to produce VOC 

emissions of approximately 0.09- 0.2 pounds ofVOC per gun produced. 

DES has determined, based on the feasibility study for implementing the available 

control technologies, submitted by Sturm, Ruger on December 21, 2009, and based on 

the fact that emissions from the process will be lower than a comparable coating process, 

that the proposed operation is RACT. 

18. Effective June 1, 2011, DES readopted Env-A 1200 (formerly Env-A 1204), with 

amendments. 
VOC RACT Order ARD-03-001 -7 -

Sturm, Ruger & Company, Inc 

19. One January 9, 2012, Sturm, Ruger submitted a request to amend the RACT Order. 

Specifically, Sturm, Ruger requested that the limit contained in Section D.S.b be changed to 

7.5 lb VOC/gallon of solution. 

D. Order 

Based on the above findings and determinations, DES hereby orders Sturm, Ruger to implement the 

following requirements as RACT: 

L. Emission Rates for Gunstock Coating 

a. In accordance with the provisions ofEnv-A 1213.03 and Env-A 1213.04 emissions from 

Woodworking Spray Booths at:ld Paint Mixing Room shall be limited, at all times, to 

rates specified in Table 2 below: 

. · · .. ,v,;, 'J!' 1 ~.~~1. 

Table 2 .'. . •., ,.~ 

. ,. '·' 

Type of Coating J.~; ·~ 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 1213.04, 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; 

111. All organic solvent used to clean spray guns shall be collected into a normally 

closed container; and 

1v. 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 1213.05 Control Techniques for Wood Furniture, Wood 

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

the facility, one or more ofthe following control techniques shall be used: 

1. High volume-low pressure (HVLP) spray; 

11. Airless spray; 

111. Air-assisted airless spray; 
VOC RACT Order ARD-03-00 I 

Stunn, Ruger & Company, Inc 

tv. Flow coating teclmiques; or 

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v. Conventional air spray under 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; 

(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 tq 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 ofEnv-A 

1213.05; or 

(6) Touch-up and repair activities in accordance with the provisions ofEnv-A 

1213.06, Compliance Standards for Touch-Up and Repair Activities at Wood 

Furniture, Wood Burial Casket, and Gunstock Coating Facilities. 

d. In accordance with Env-A 1213.06, 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.l.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; or 

(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 10 gallons 

per day where such activities employ: 

(I) The use of aerosol containers; or 
VOC RACT Order ARD-03-00 l -9 -

Sturm, Ruger & Company, Inc 

(2) One or more non-compliant coating materials in conjunction with any of the 

application techniques listed in Section D .l.c. above. 

2. Compliance Standards for Cold Cleaning 

In accordance with the provisions ofEnv-A 1221.02(a)(l)c and Env-A 1221.02(a)(2), 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 1 0 pounds per square inch as 

measured at the pump outlet; and 

11. Performed only within the confines ofthe 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 the powder coating operation, 

at all times, to 1.0 lbs ofVOC per gallon of coating, as applied, excluding water and 

exempt compounds. 

b. In accordance with the provisions ofEnv-A 1212.04(b)(l), the VOC emission rate from 

the Rustproofing operation shall be limited at all times to 3.5 lbs of VOC per gallon of 

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

the following: 

1. ACA-RP-2, or replacement, shall be limited to 6.34lbVOC/gal coating; and 

11. Pen Dip Super, or replacement, shall be limited to 5.2 lb VOC/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. 

d. Coatings used in the Camouflage Coating Process shall be limited to the following: 

1. For a clear or transparent top coat, 4.3 lb VOC/gal coating; and 

11. For a coating that is air dried, 3.5 lb VOC/gal coating. 
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Sturm, Ruger & Company, Inc 

4. General Compliance Standards for Plastic Parts Coating 

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a. One of the following control techniques shall be used for the Camouflage Coating 

Process: 

1. High volume, low pressure (HVLP) spray; 

11. Electrostatic spray; 

111. Zinc-arc spray; 

1v. Air-assisted airless spray; 

v. Airless spray; or 

v1. A flow coating technique. 

5. Applicability Criteria for Miscellaneous and Multicategory Stationary VOC Sources 

a. For Flash Dewax process: 

1. In accordance _with the provisions ofEnv-A 1222.02(a)(l), Sturm, Ruger shall 

comply with VOC RACT by meeting the· presumptive norm of 81% control. 

u. Sturm, Ruger shall operate each flash dewax oven at a minimum temperature of 

800° F when molds are in the oven. 

111. Each thermocouple and temperature controller shall be calibrated quarterly 

according to manufacturer's specifications in order to maintain a nominal furnace 

temperature of 1 ,000°F1. 

b. For the Camouflage Image Transfer process the VOC content of the activator/release 

agent shall be limited to 7.5 lb VOC/gallon of solution. 

6. Minor Core Activities 

Pursuant to Env-A 1201.04(c), minor core activities are exempt from the VOC RACT 

requirements ofEnv-A 1200. 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 1222.02 for unclassifiable processes. 

7. Monitoring 

a. The owner or operator of a solvent metal cold cleaner shall use visual inspection for 

compliance with equipment specificatio!J.S and operating procedures. 

b. For the Flash Dewax Oven the operator shall: 

1. Maintain the ovens at a minimum temperature of 800° F while molds are in the 

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

the furnace. This results in oven temperatures that are typically near I ,000°F, however there are times during normal 

operation when the oven temperature goes below I ,000°F. 
ovens; 

VOC RACT Order ARD-03-00 I 

Sturm, Ruger & Company, Inc 

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11. Calibrate each thermocouple and temperature controller quarterly according to 

manufacturer's specifications in order to maintain nominal oven temperature of 

l,OoooF; 

HI. Continuously monitor and record the temperature of the Flash Dewax ovens2; 

IV. Readings before and after adjustment should be recorded; if no adjustments are 

necessary, that should also be recorded; 

v. On all records, include identification ofthe instrument component calibrated, the 

date of calibration, and the initials of the person who performed the calibration. 

8. 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; 

u. Record the monthly VOC emissions from each operation; 

111. Report the information recorded pursuant to i. and ii., above, to DES annually by 

April 15th for each preceding calendar year; 

1v. Maintain records of the calibration and temperature readings for flash dewax ovens 

on site for inspection. 

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, demonstrate compliance with processes listed 

in D .1. and D .3. 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: 

2 Continuous recording will mean that electronic temperature readings shall be taken at regular time intervals, not to 

exceed five minutes between readings. For ovens that currently do not have continuous recording capability, the 

temperature shall be recorded prior to the processing of parts. 
VOC RACT Order ARD-03-001 

Sturm, Ruger & Company, Inc 

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

X= Weight fraction of VOC in the mixed coating 

Yw= Volume fraction of water in the mixed coating 

Ye= 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 1200, 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. 

Please address any correspondence and communication in reference to this Order to: 

Ms. Barbara Dorfschmidt 

NHDES, Air Resources Division 

29 Hazen Drive, P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6796 

cc: Timothy Drew, NHDES, PIP Office 

David Conroy, US EPA 

Town Selectmen 

Assistant Director 

Air Resources Division