ATTACHMENT C-4 

Emission Reduction Calculations for 

Automotive Refinishing Operations 

R.C .S.A. Section 22a-174-3b(d) 

Back2round 

New R.C.S .A. Section 22a-174-3b establishes emissions limitations, operating practices and 

record keeping requirements for automotive refinishing operations as well as other source 

categories to restrict emissions to levels that are not significant contributions to air pollution. 

The regulation also exempts covered sources from the permitting process by removing owners 

and operators from the duty to apply for and obtain individual operating permits. 

Specifically, 22a-174-3b(d) requires the owner or operator of an automotive refinishing 

operation who chooses to operate under 22a-174-3b(d) in lieu of obtaining an individual permit 

to : 

1) limit usage of VOC-containing coatings or solvents to no more than 2000 gallons in any 

12-month period ; 

2) apply paint and coatings with high-volume low-pressure (HVLP) spray equipment, 

electrostatic application equipment, or other application methods with a guaranteed 

transfer efficiency of at least 65%; and 

3) conduct spraying and cleaning operations in accordance with specified standards intended 

to further limit emissions. 

Sources that exceed the specified 2000 gallon annual limit must apply for and obtain an 

individual permit under R.C.S.A. Section 22a-174-3a. Permitting requirements for operation of 

such sources would be at least as stringent as those specified above. 

Connecticut's regulation has equivalent requirements to those specified in the model rule 

developed by the Ozone Transport Commission (OTC), as contained and described in 

Connecticut's State Implementation Plan (SIP) revision: Update to the Ozone Attainment 

Demonstration for the Southwest Connecticut Severe Ozone Nonattainment Areal dated 

October 15, 2001 . Emission reduction calculations for Connecticut were determined based on 

the methods used by the OTC and are documented below. 

Emission Calculations 

OTC's methodology, consistent with the base year inventories used in photochemical modeling 

and in EPA's shortfall calculations, employed a 1990-era EPA emission factor2 to represent 

1 A general description of OTC's model rule is provided in Section 4.1 of Attachment 2 to that SIP revision. The OTC model rule and associated emission reduction calculations can be found in Enclosures D and C, respectively, of the same SIP revision . Applicable OTC calculation methods have been incorporated into the Deprtment's emission reduction estimates presented above. The complete SIP document can be accessed on the internet at : http ://www.den .state .ct.us/air2/siprac/2001/sup2 htm . 

2 See Table 4.3-6 of Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone; EPA-450/4-91-016 ; May 1991 . The document can be accessed on the internet at: 
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uncontrolled emissions from automobile refinishing facilities . Uncontrolled emission estimates 

do not include the reductions resulting from either EPA's national VOC content rule 

promulgated in 1998 or Connecticut's R.C.S.A. Section 22a-174-3b requirements. 

To ensure consistency with OTC's emission reduction calculations for the remainder of the 

Ozone Transport Region (OTR), including the New York City nonattainment area, the 

Department's analysis uses a per capita emission factor of 2.3 pounds per capita per year to 

calculate uncontrolled emissions for the mandated attainment year of 2007 . Subsequent 

calculations provide estimates of 2007 emissions including EPA's national VOC limits and the 

combination of the national requirements and Connecticut's R.C.S .A. Section 22a-174-3b. 

2007 Uncontrolled Emissions 

Where: 

Eunc = EFunc x Pop2oo7 x CF 

Eu c = 2007 uncontrolled emissions (tons/day) 

EF nc = 2.3 lbs/(capita x year) 

Pop2oo7 = Connecticut estimated 2007 population, extrapolated 

from US Census Bureau estimates for 1999 - 2003 

= 3,580,906 

CF = conversion factor 

= (1 ton/2000 lbs) x (1 year/(5 work days x 52 weeks)) 

= 1 .923 x 10"6 

Application of this formula for Connecticut yields : 

2007 Uncontrolled Emissions = 15 .8 tons/day 

2007 Emissions with EPA's National VOC Limits 

EPA's 1998 VOC content limits result in an estimated 37% reduction 3 in emissions from 

uncontrolled levels, including EPA's assumption of 100% rule effectiveness: 

2007 Emissions with EPA Rule = 15.8 tonslday (1-0 .37) 

= 10.0 tons/day 

2007 Emissions with EPA's National VOC Limits and Connecticut's Regulation 

OTC's analysis determined that the use of HVLP spray equipment (or equivalent) would result in 

35% reduction in VOC emissions, with an additional 3% reduction due to the requirement for 

enclosed spray gun cleaners . Connecticut's R.C.S .A. Section 22a-174-3b(d) includes both 

requirements (totaling 38% reduction beyond EPA's rule), resulting in a 2007 VOC emission 

estimate of: 

h ://www.e a. 

ov/ttn/chief/old/eidocs/450491016 voll ma 1991 . df . 

R -A-+,-"C 'from the Architectural and Industrial 

3 "Credit for the 15 Percent Rate-01-Progress Plans for c 

Maintenance (AIM) Coating Rule and the Autobody Refinishing Rule." Memorandum from John Sietz, USEPA 

Office of Air Quality Planning and Standards to USEPA Regional Air Directors. 11/29/1994 . 
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" Assuming 100% rule effectiveness : 

2007 Emissions with EPA Rule and the 

Connecticut Rule = 10.0 tons/day (1 - (0.38 * 1 .0)) 

= 6.2 tons/day 

" Assuming 80% rule effectiveness : 

2007 Emissions with EPA Rule and the 

Connecticut Rule = 10.0 tons/day (1 - (0.38 * 0.8)) 

= 7 .0 tons/day 

Incremental Shortfall Credit Due to Connecticut's Regulation 

Reductions creditable toward the shortfall are the difference between 2007 emissions with only 

the EPA VOC limits and 2007 emissions with both the EPA VOC limits and R.C.S .A. Section 

22a-174-3b. Accounting for a range of possible rule effectiveness: 

" Assuming 100% rule effectiveness : 

Shortfall Credit = 10.0 tons/day - 6 .2 tons/day 

= 3.8 tons/day 

" Assuming 80% rule effectiveness: 

Shortfall Credit = 10.0 tons/day - 7.0 tons/day 

= 3 .0 tons/day 

Based on the above analysis, R.C.S.A. Section 22a-174-3b will result in between 3 .0 and 3 .8 

tons/day additional VOC reduction beyond those incorporated into the Department's ozone 

attainment plan and EPA's calculation of Connecticut's emission reduction shortfall. By the end 

of 2004, the Department plans to complete a mid-course review evaluating progress toward 

attainment of the 1-hour ozone standard in Connecticut. That document will include a discussion 

of how the combined reductions from the automotive refinishing regulation and other adopted 

control measures are sufficient to meet EPA's shortfall requirement for Connecticut.