~ State of New Hampshirt. 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

Thomas S. Burack, Commissioner 

February 4, 2013 

Mr. Curt Spalding, Administrator 

USEPA Region I 

5 Posli Office Square 

Suite 100 

Boston, MA 02109-3912 

Re: SIP Revision Proposal for VOC RACT Order No. ARD-03-001 

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

Facility Identification #3301900025 

Dear Mr. Spalding: 

Pursuant to section 1 I 0 of the Clean Air Act and as Governor Margaret Hassan's designee, I hereby 

submit for your approval a proposed revision to the State Implementation Plan (SIP). An electronic version of 

this submittal, which is an exact duplicate of the paper version, is enclosed on a disk. This revision involves 

amendments to a Volatile Organic Compound (VOC) Reasonably Available Control Technology (RACT) Order 

issued in accordance with the revised New Hampshire Code of Administrative Rules, Env-A 1222, 

Miscellaneous and Multicategory Stationary VOC Sources (formerly Env-A 1204.49), to Sturm, Ruger & 

Company, Inc. (Sturm Ruger) for its facility in Newport, New Hampshire. 

On May 31 , I 995, Sturm Ruger submitted an initial VOC RACT compliance plan for operations 

associated with firearm manufacturing facility. Based on this application, along with subsequent submittals 

made in 2001 and 2002, the New Hampshire Department of Environmental Services, Air Resources Division 

(DES) issued the initial VOC RACT Order No. ARD-03-00 I to Sturm Ruger on October 13, 2003. DES 

submitted the VOC RACT Order as a SIP revision on October 13, 2003. The VOC RACT Order, along with the 

SIP revision submittal, was amended on December 1, 2003, in response to comments received from the United 

States Environmental Protection Agency (USEPA). On November 15, 20 12 the USEPA approved the Order 

into the New Hampshire SIP, effective January 4, 2013. 

On November 19, 201 0, Sturm Ruger submitted an application for the installation of a Camouflage 

Image Transfer and Coating Process Line and a new Stainless Steel Bluing Line. The VOC RACT Order was 

amended on March 2, 2010 to include these new process lines. The Order was subsequently amended on March 

21, 2012 to update the limit for the Camouflage Image Process Line. 

Order: 

This SIP revision proposal includes the following documentation covering the amended VOC RACT 

• A copy of the public notice published on January 20, 2010. Note that this public notice pertains to 

the amended order issued on March 2, 2010. The amended order issued on March 21,2012 did not 

result in an increase in emissions; therefore, a public notice was not published for that amendment. 

• DES proposed VOC RACT Order letter dated January 20, 2012; 

• DES final VOC RACT Order issuance letter dated March 21, 20 12; and 

• Final VOC RACT Order issued on March 21,2012. 

Since the last SIP revision submittal on December I, 2003, the most recent VOC RACT Order has been 

amended to detail the VOC RACT requirements for the new Camouflage Image Transfer and Coating 

Process Line and the new Stainless Steel Bluing Line as detailed below: 

DES Web site: www.des.nh.gov 

P.O. Box 95, 29 Ilazen Drive, Concord, New Hampshire 03302-0095 

Telephone: (603) 271-1370 • Fax: (603) 271-1381 • TDD Access: Relay NH 1-800-735-2964 
Mr. Curl Spalding 

SIP Revision Proposal for VOC RACT Order No. ARD-03-00/ 

February 4, 20 I 3 

Page2 

• Coating limit for the new Stainless Steel Bluing Line was added as Condition D.3.b.ii; 

• Conditions relating to the Camouflage Coating Process were added as Condition DJ.d, Condition 

0.4 and Condition D.S.b. Note that the limit contained in Condition D.S.b. was amended on 

March 21,2012. 

• Conditions previously numbered as 0.4 to 0.7 were renumbered as 0.5 to 0.8. 

Should you require further information, please contact Barbara Dorfschmidt of the Air Resources 

Division, Permitting and Environmental Health Bureau at (603) 27 I -6796 or via e-mail at 

barbara.dorfschmidt@des.nh.gov. 

C/\W/bdd 

Enclosures 

cc: David Conroy, USEP/\ 

Town Clerk - Newport NH 

Tim Drew - PIP 

Don Olesen - Sturm Ruger & Company, Inc. 

Ida McDonnell - USEP/\ 

Sincerely, 

f.:iwC::oi)-

Acting Director 

Air Resources Division