## 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 fromthe permitting process by removing owners and operators fromthe 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 Ageneral description of OTC's model rule is provided in Section 4 .1 ofAttachment 2 to that SIP revision. The OTCmodel rule and associated emission reduction calculations can be found in Enclosures Dand C, respectively, of the same SIP revision. Applicable OTCcalculation 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:2 C-4 uncontrolled emissions fromautomobile refinishing facilities. Uncontrolled emission estimates do not include the reductions resulting from either EPA's national VOCcontent 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 ofthe 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

fromUS 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 VOCLimits EPA's 1998 VOCcontent limits result in an estimated 37% reduction3 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 VOCLimits and Connecticut's Regulation OTC's analysis determined that the use of HVLP spray equipment (or equivalent) would result in 35% reduction in VOCemissions, 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 VOCemission estimate of

:

h ://www

.e a. ov/ttn/chief/old/eidocs/450491016 voll ma 1991 . df . R 'from

the Architectural and Industrial -A-+,-"C 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 ofAir Quality Planning and Standards to USEPA Regional Air Directors. 11/29/1994.3 C-4 " 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 EPAVOC limits and 2007 emissions with both the EPAVOClimits 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 reviewevaluating progress toward attainment of the 1-hour ozone standard in Connecticut . That document will include a discussion of how the combined reductions fromthe automotive refinishing regulation and other adopted control measures are sufficient to meet EPA's shortfall requirement for Connecticut .