Connecticut Department of

"ENERGY &

ENVIRONMENTAL

PROTECTION

79 Elm Street  ̄ Hartford, CT 06106~5127 www.ct.gov,/deep Affirmative Action/Equal Opportunity Employer"

November 21, 2012

David B. Conroy, Chief

Air Programs Branch

United States Environmental Protection Agency - Region 1

5 Post Office Square - Suite 100

Boston, MA~02109-3912

Revision to the Connecticut State Implementation Plan --

Reasonably Available Control Technology Update to Address a 2008

Control Techniques Guideline

Dear Mr. Conroy:

This package is a revision to the State Implementation Plan (SIP) concerning the RACT

requirements for volatile organic compounds (VOC) in response to the U.S. Environmental

Protection Agency’s (EPA’s) adoption of a control techniques guideline (CTG) in 2008 for

miscellaneous metal and plastic parts coating (EPA-453/R-08-003-2008/09). Pursuant to 40

CFR 51, Appendix V, Section 2.1 (a), a copy of the final regulation implementing the CTG and

documentation of the public hearing are provided. An electronic copy of this submission has

also been mailed to the copy recipients listed below, and I certify that such copies are an exact

copy of this paper submission.

Effective October 31, 2012, the Connecticut Department of Energy and Environmental

Protection (DEEP) revised RCSA section 22a-174-20(s) and adopted RCSA section 22a-174-

20(kk) to address the requirements of the miscellaneous metal and plastic parts coatings CTG.

Effective the same date, DEEP also revised RCSA section 22a-174-20(aa)(1) and (cc)(2) and (3),

which revisions are necessary given the revision to subsection (s) and adoption of subsection

(kk). The submission also makes a clarification to RCSA section 22a-174-20(ii)(3)(A). All of

these revisions are elements of this SIP revision and are submitted for approval as part of the

regulatory text in Attachment A.

All required state and federal procedures for public participation and in satisfaction of the

requirements of 40 CFR 5 t, Appendix V, Section 2 were followed. To demonstrate satisfaction

of the federal public participation requirements, we have enclosed: a certified copy of the

regulatory revisions; the public notice; a list of attendees at the public hearing; certification of

public hearing; and a hearing report, which summarizes comments received, identifies the

commenters and describes changes made as a result of the comments. The submitted

attachments are as follows:

Attachment A Revisions to RCSA section 22a-174-20, effective on 31 October 2012, in the

form filed with the Secretary of the State, marked with brackets and underlined

text to show the changes to the current SIP requirements.
Page 2

David B. Conroy

November 2I, 2012

Attachment B

Attachment C

Public notice as published in the Connecticut Law Journal and on the DEEP

website on 27 September 2011.

Attendees at the public hearing on 9 November 2011, DEEP Headquarters, 79

Elm Street, Hartford, CT

Attachment D Certification of public hearing

Attachment E Hearing report

Attachment F Copy of the report of the Legislative Commissioners’ Office

Attachment G Regulatory Assessment Document

DEEP finds the adopted requirements to be at least as stringent as the requirements of the

underlying 2008 CTG. DEEP has addressed the design of the adopted requirements, including

certain aspects that vary from the CTG, in the Regulatory Assessment Document (Attachment G)

and, to a lesser extent, the hearing report (Attachment E). We hope you find this information

helpful in reviewing and ultimately approving this SIP revision. If you require additional

information or have any questions about this submission, please get in touch with Merrily Gere

of the Bureau of Air Management at (860) 424-3416 or merril¥.gere@ct.~ov.

Sincerely,

Anne R. Gobin

Chief, Bureau of Air Management

Anne Arnold, EPA Region 1

Robert McConnell, EPA Region 1
Attaclmaent A

Revisions to RCSA section 22a- 174-20
Office of the Secretary of the State

State of Connecticut

RO. Box 150470, Hartford, CT 06115-0470

~)ENISE W. MERRILL

Secretary of the State

JAMES FIELD ~;PALLONE

Deputy Secretary of the State

November 7, 2012

Daniel Esty, Commissioner

Department of Energy and Envirolmlental Protection

79 Elm Street

Hartford, CT 06105

Agency Regulation Concerning:

Amendment of Section 22a-174-20 of the Regulations of Connecticut State

Agencies: Control of Organic Compound Emissions

Regulation Review Committee Docket Number: 2012-24a

Secretary of the State File Number: 6087

Dear Commissioner Esty:

This is to acknowledge receipt of two copies of the above referenced regulation issued by the

Department of Energy and Environmental Protection. One of the two copies has been forwarded

to the Commission on Official Legal Publications as required by law.

Said regulation was received and filed in this office on October 31, 2012. The effective date of

this regulation is October 31, 2012.

We request that you please forward the original or a copy of this acknowledgement letter

to your agency’s legal services department, and]or to the agency department responsible

for adopting the regulation, for its files.

Sincerely,

Sladek

RLS Assistant Coordin~or

860-509-6147

CC: Commission on Official Legal Publications (Letter and Copy of Regulation)

File

Commercial Recording Division (860) 509-600! fax (860) 509-6069 State Capitol Office

Legislation and Election Administration Division (860) 509-6100 fax (860) 509-6127 Deputy Secretary of ttle State

General Information (860) 509-6000 Management & Support Services

Internet Horae Page: www.sots.ct.gov

(860) 509-6200 fax (860) 509-6209

(860) 509-62!2 fax (860) 509-613!

(860) 509-6190 fax (860) 509~6175
R-39 Rev. 02/20i2 Page 1 of 36

State of Commcticut

of

NAME OF AGENCYDepartment of Energy and Enviromnental Protection

tioncerning

SUBJECT MATTER OF REGULATION

Amendment of Section 22a-174-20 of the

Regulations of Connecticut State Agencies

Control of O~P°und Emissions

Section I. Subsection (s) of section 22a-174-20 of the Regulations of Connecticut State Agencies is

amended to read as follows:

(~) ]Vliscellaneons metal ~ parts [and products.] ~

[(1) For the purpose of this subsection:

Air dried coatng" means a coating that is dried by the use of air or forced wam~ air at temperatures up

below 90 degrees C (194 degrees F).

"Clear coat" means a base or top coating which either lacks color and opacity or which is transparent and

uses the surface to which it is applied as a reflectant base or undm-tone color.

"Coating applicatmn systen" means all operations and equipment that apply, convey and dry a surface

coating, including, but not limited to, spray bootbs, flow coaters, flashoff areas, air dryers and ovens.

"Exposure to extreme environmental conditions" means exposure to: the weather all of the time;

temperatures consistently above 95 degrees C; detergents; abrasive and scom’ing agents; solvents;

corrosive atmospheres; or similar enviromnental conditions as detemained by the commissioner and the

Administrator. ’

extreme environmental

"Extreme perfon~ance coat ng means coatings designed for exposure to

conditions.

"Heat sensitwe materal" meaus materials that cannot consistently be exposed to ~ ~ o

95 degrees C (203 degrees F) for more than 30 seconds.

coating that is applied to arehitectu~/

"High performance architectural alummum coatmg means A~,~A"

"

a

subsections to meet the specifications of publication number aluminum panels, extrusions or ’s Association.

605.2-1992 of the Architectaral Aluminum Manufacturer

"Prime coat" means the first of two or more films of coating applied to a metal surface.

"Single coat" means one film of coating applied to a metal surface.

"Topcoat" means the final film or series of films of coating applied in a two-coat (or more) operation.

.... cans the portion of coating solids that adheres to the metal surface during the "Transfer effimency m

app ication process, expressed as a percentage of the total volume of coating solids delivered by the

applicator.
Page 2 of 36

R-39 Rev. 02/2012

(2) Applicability. For the purpose of this subsection: 

(A) Miscellaneous metal parts and products includes the following industrial categories:

(i) Large farm machinery such as harvesting, fertilizing and planting machines, 

tractors, combines, etc.,

(ii) Small farm machinery such as lawn and garden tractors, lawn mowers, rototiller, 

etc.,

(iii) Small appliances such as fans, mixers, blenders, crock pots, dehumidifiers, 

vacuum cleaners, etc.,

(iv) Commercial machinery such as office equipment, computers and auxiliary 

equipment, typewriters, calculators, vending machines, etc.,

(v) Industrial machinery such as pumps, compressors, conveyor components, fans, 

blowers, transformers, etc.,

(vi) Fabricated metal products such as metal covered doors, frames, etc., and 

(vii) Any other industrial category which coats metal parts or products under the 

Standard Industrial Classification Code of Major Group 33 (primary metal 

industries), Major Group 34 (fabricated metal products), Major Group 35 

(nonelectric machinery), Major Group 36 (electrical machinery), Major Group 37 

(transportation equipment), Major Group 38 (miscellaneous instruments), Major 

Group 39 (miscellaneous manufacturing industries), Major Group 40 (Railroad 

Transportation) and Major Group 41 (Transit Passenger Transportation); and

(B) Miscellaneous metal parts and products excludes the following items:

(i) automobiles and light duty trucks,

(ii) metal cans,

(iii) flat metal sheets and strips in the form of rolls or coils,

(iv) plastic and glass objects,

(v) magnet wire for use in electrical machinery,

(vi) metal furniture,

(vii) the exterior surface of assembled aircraft,

(viii) automobile refinishing,

(ix) customized top coating of automobiles and trucks, if production is less than 5 

vehicles per day, and

(x) the exterior surface of assembled marine vessels.
Page 3 of 36

R-39 Rev. 02/2012

(3) Emission standards. No owner or operator of a facility engaged in the surface coating of 

miscellaneous metal parts and products may operate a coating application system subject to this 

subsection that emits volatile organic compounds from any coating in excess of:

(A) 0.52 kg/l (4.3 lb/gal) of coating, excluding water and exempt volatile organic compounds 

listed in 40 CFR 51.100(s) as amended from time to time, delivered to a coating 

applicator that applies a clear coat;

(B) 0.42 kg/l (3.5 lb/gal) of coating, excluding water and exempt volatile organic compounds 

listed in 40 CFR 51.100(s) as amended from time to time, delivered to a coating 

applicator in a coating application system that is air dried or forced warm air dried at 

temperatures up to 90 degrees C (194 degrees F);

(C) 0.42 kg/l (3.5 lb/gal) of coating, excluding water and exempt volatile organic compounds 

listed in 40 CFR 51.100(s) as amended from time to time, delivered to a coating 

applicator that applies extreme performance coatings;

(D) 0.36 kg/l (3.0 lb/gal) of coating, excluding water and exempt volatile organic compounds 

listed in 40 CFR 51.100(s) as amended from time to time, delivered to a coating 

applicator for all other coatings, adhesives, fillers or sealants and coating application 

systems; and

(E) 0.75 kg/l (6.3 lb/gal) of coating, excluding water and exempt volatile organic compounds 

listed in 40 CFR 51.100(s) as amended from time to time, delivered to a coating 

applicator which applies high performance architectural aluminum coatings, provided 

that:

(i) such applicator is located at a premises which emits three thousand three hundred 

thirty three (3,333) pounds of volatile organic compounds per month or less from 

such applicator, and

(ii) such applicator was an existing source in Connecticut on or before November 1, 

1994.

(4) This subsection applies to all application areas, flashoff areas, air and forced air dryers and ovens 

used in the surface coating operations pertaining to miscellaneous metal parts and products listed in 

subsection (s)(2) of this section. This regulation also applies to prime coat, top coat and single coat 

operations.

(5) If more than one emission limitation in subsection (s)(3) of this section applies to a specific 

coating, then the least stringent emission limitation shall be applied.

(6) All volatile organic compound emissions from solvent washings shall be considered in the 

emission limitations in subsection (s)(3) of this section unless the solvent is directed into containers that 

prevent evaporation into the atmosphere.

(7) The provisions of this subsection apply to any premises that has actual emissions of volatile 

organic compounds of fifteen (15) pounds per day or more in any one day from all miscellaneous metal 

parts and products surface coating operations on such premises unless:

(A) The total potential emissions from all surface coating operations are limited by permit or 

order of the commissioner to 1,666 pounds or less in any calendar month;
Page 4 of 36

R-39 Rev. 02/2012

(B) The owner or operator is and has at all times been in compliance with such limitation 

since the issuance of the permit or order;

(C) The total actual emissions from all such surface coating operations have not exceeded 

1,666 pounds in any calendar month since January 1987; and

(D) Notwithstanding subsections (A) through (C) of this subdivision, any surface coating 

operation on such premises that emitted 40 pounds or more in any day and that was 

subject to the requirements of this subsection prior to November 1, 1989, shall remain 

subject to the provisions of this subsection.

(8) After November 1, 1989 any premises that is or becomes subject to the provisions of this 

subsection shall remain subject to the provisions of this subsection unless the owner or operator meets the 

requirements of subparagraphs (A), (B) and (C) of subdivision (7) of this subsection.

(9) The owner or operator of any surface coating operation that was not subject to the requirements 

of this subsection prior to November 1, 1989, shall have until October 1, 1990, to comply with the 

requirements of this subsection for such system.

(10) Notwithstanding the requirements of this subsection, an owner or operator may use, in the 

aggregate, up to fifty-five (55) gallons of coatings that exceed the emission limitations set forth in 

subdivision (3)(A) through (3)(E), inclusive, of this subsection at such premises for any twelve (12) 

consecutive months, provided such owner or operator maintains records of such coatings in accordance 

with subsection (aa) of this section. ]

(1) Definitions. For the purpose of this subsection, the following definitions apply:

“Ablative coating” means a coating that chars when exposed to open flame or extreme temperatures, as 

would occur during the failure of an engine casing or during aerodynamic heating, to protect adjacent 

components from the heat or open flame;

“Adhesion promoter” means a very thin coating applied to a substrate to promote wetting and form a 

chemical bond with the subsequently applied material;

“Adhesive bonding primer” means a primer applied in a thin film to aerospace components to inhibit 

corrosion and increase adhesive bond strength;

“Aerospace high temperature coating” means a coating designed to withstand temperatures of more than 

350°F;

“Aerospace vehicle or component” means any fabricated part, processed part, assembly of parts, or 

completed unit, with the exception of electronic components, of any aircraft including but not limited to 

airplanes, helicopters, missiles, rockets and space vehicles;

“Air dried” means cured at a temperature below 90oC (194 oF);

“Airless spray application” means a coating spray application system using high fluid pressure, without 

compressed air, to atomize the coating;

“Air-assisted airless spray application” means a coating spray application system using fluid pressure to 

atomize the coating and lower pressure air to adjust the shape of the spray pattern;

“Antichafe coating” means a coating applied to areas of moving aerospace components that may rub 

during normal operations or installation;
Page 5 of 36

R-39 Rev. 02/2012

“Antique aerospace vehicle” means an aircraft or component thereof that was built at least 30 years ago

and that is not routinely in commercial or military service in the capacity for which it was designed;

“Appurtenance” means any accessory to a stationary structure, including but not limited to: bathroom 

and kitchen fixtures; cabinets; concrete forms; doors; elevators; fences; hand railings; heating equipment, 

air conditioning equipment, and other fixed mechanical equipment or stationary tools; lampposts; 

partitions; pipes and piping systems; rain gutters and downspouts; stairways; fixed ladders; catwalks; fire 

escapes and window screens;

“As applied” means the composition of coating at the time it is applied to a surface, including any solvent, 

catalyst or other substance added to the coating but excluding water and exempt compounds;

"Automotive-transportation part" means an interior or exterior component of a motor vehicle or mobile 

source;

“Baked” means cured at a temperature at or above 90°C (194°F);

“Base coat” means the initial coating applied to a substrate in a process of applying two or more coatings;

“Bearing coating” means a coating applied to an antifriction bearing, a bearing housing or the area 

adjacent to such a bearing to facilitate bearing function or to protect base material from excessive wear.

“Bearing coating” does not include a material that can also be classified as a dry lubricative material or a 

solid film lubricant;

“Bonding maskant ” means a temporary coating used to protect selected areas of aerospace parts from 

strong acid or alkaline solutions during processing for bonding;

“Business machine” means a device that uses electronic or mechanical methods to process information, 

perform calculations, print or copy information or convert sound into electrical impulses for transmission,

such as, typewriters, electronic computing devices, calculating and accounting machines, telephone and 

telegraph equipment and photocopy machines;

“Camouflage coating” means a coating used, principally by the military, to conceal equipment from 

detection;

“Capture efficiency” means the ratio of VOC emissions delivered to the control device to the total VOC 

emissions resulting from the miscellaneous metal and plastic parts coating operation, expressed as a 

percentage;

“Caulking and smoothing compound” means a semi-solid material that is applied by hand and used to 

smooth exterior vehicle surfaces or fill cavities such as bolt hole accesses. “Caulking and smoothing 

compound” does not include a material that can also be classified as a sealant;

“Chemical agent-resistant coating” means an exterior topcoat designed to withstand exposure to chemical 

warfare agents or the decontaminants used on these agents;

“Chemical milling maskant” means a coating that is applied directly to aluminum components to protect 

surface areas when chemically milling the component with a Type I or II etchant. “Chemical milling 

maskants” do not include bonding maskants, critical use and line sealer maskants, seal coat maskants, 

maskants that are defined as specialty coatings or maskants used with either a Type I or II etchant plus a 

bonding maskant, critical use and line sealer maskant or seal coat maskant;
Page 6 of 36

R-39 Rev. 02/2012

“Cleaning solvent” means any VOC-containing liquid, including a liquid impregnated wipe or towelette, 

used in cleaning;

“Clear coating” means a colorless coating that contains binders but no pigment and that is formulated to 

form a transparent film;

“Coating” means a material that is deposited in a thin, persistent, uniform layer across the surface of a 

substrate for aesthetic, protective or functional purposes, including but not limited to, paints, primers, inks

and maskants. “Coating” does not include protective oils, acids and bases;

“Coating unit” means a series of one or more coating applicators and any associated drying area or oven 

wherein a coating is applied, dried or cured. A “coating unit” ends at the point where the coating is dried 

or cured, or prior to any subsequent application of a different coating;

“Commercial exterior aerodynamic structure primer” means a primer used on aerodynamic components 

and structures that protrude from the fuselage, such as wings and attached components, control surfaces, 

horizontal stabilizers, vertical fins, wing-to-body fairings, antennae and landing gear and doors for the 

purpose of extended corrosion protection and enhanced adhesion;

“Commercial interior adhesive” means a material used in the bonding of passenger cabin interior 

components;

“Compatible substrate primer” means one of the following coatings:

(A) A primer that is compatible with the filled elastomeric coating and is epoxy based,

(B) A primer that inhibits corrosion and is applied to bare metal surfaces or is applied prior to 

adhesive application, or

(C) A primer that is applied to surfaces, excluding fuel tanks, that can be expected to come 

into contact with fuel;

“Control device efficiency” means the ratio of VOC emissions recovered or destroyed by the control 

device to the total VOC emissions that are introduced into the device, expressed as a percentage;

“Corrosion prevention compound” means a coating system that provides corrosion protection by 

displacing water and penetrating substrates, forming a protective barrier between the metal surface and 

moisture. “Corrosion prevention compound” does not include a coating containing oils or waxes;

“Critical use and line sealer maskant” means a temporary coating, not covered under other maskant 

categories, used to protect selected areas of aerospace parts from strong acid or alkaline solutions such as 

those used in anodizing, plating, chemical milling and processing of magnesium, titanium or high A8 

strength steel, high-precision aluminum chemical milling of deep cuts and aluminum chemical milling of 

complex shapes, and includes materials used for repairs or to bridge gaps left by scribing operations; 

“Cryogenic flexible primer” means a primer designed to provide corrosion resistance, flexibility and 

adhesion of subsequent coating systems when exposed to loads up to and surpassing the yield point of the 

substrate at cryogenic temperatures (-275°F and below);

“Cryoprotective coating” means a coating that insulates cryogenic or subcooled surfaces to limit 

propellant boil-off, maintain structural integrity of metallic structures during ascent or re-entry and 

prevent ice formation;
Page 7 of 36

R-39 Rev. 02/2012

“Cyanoacrylate adhesive” means a fast-setting, single component adhesive that cures at room temperature 

and contains methyl, ethyl, methoxymethyl or other functional groupings of cyanoacrylate;

“Dip coating” means a method of applying a coating to a surface by submersion into and removal from a 

coating bath;

“Drum” means any cylindrical metal container larger than 12 gallons capacity and less than or equal to 

110 gallons capacity; 

“Dry lubricative material” means a coating consisting of lauric acid, cetyl alcohol, waxes or other noncross linked or resin-bound materials that act as a dry lubricant;

“Electric dissipating coating” means a coating that rapidly dissipates a high-voltage electric charge;

“Electric-insulating and thermal-conducting coating” means a coating that displays an electrical insulation 

of at least 1000 volts DC per mil on a flat test plate and an average thermal conductivity of at least 0.27 

BTU per hour-foot-degree-Fahrenheit;

“Electric-insulating varnish” means a coating applied to electric motors, components of electric motors or 

power transformers to provide electrical, mechanical and environmental protection or resistance;

“Electric or radiation-effect coating” means a coating or coating system engineered to interact, through 

absorption or reflection, with specific regions of the electromagnetic energy spectrum, such as the

ultraviolet, visible, infrared or microwave regions and which may be used for lightning strike protection, 

electromagnetic pulse (EMP) protection and radar avoidance.

“Electrostatic application” means a method of applying coating particles or coating droplets to a grounded 

surface by electrically charging such particles or droplets;

“Electrostatic discharge and electromagnetic interference coating” or “EMI coating” means a coating 

applied to space vehicles, missiles, aircraft radomes and helicopter blades to disperse static energy or 

reduce electromagnetic interference;

“Electrostatic preparation coating” means a coating applied to a plastic part solely to provide conductivity 

for the subsequent application of a primer, a topcoat or other coating through the use of electrostatic 

application methods;

“Elevated-temperature Skydrol-resistant commercial primer” means a primer applied primarily to

commercial aircraft or commercial aircraft adapted for military use that withstands immersion in 

phosphate-ester hydraulic fluid (Skydrol 500b or equivalent) at the elevated temperature of 150°F for 

1,000 hours;

“EMI/RFI shield coating” means a coating that functions to attenuate electromagnetic interference, radio 

frequency interference signals or static discharge;

“Epoxy polyamide topcoat” means a coating containing epoxy and a polyamide component used to 

provide a hard, durable, chemical-resistant finish;

“Etching filler” means a coating that contains less than 23% solids by weight and at least 0.5% acid by 

weight and is used as a substitute for the application of a pretreatment coating followed by a primer; 

“Exempt compound” means a carbon compound excluded from the definition of “volatile organic 

compound,” as defined in section 22a-174-1 of the Regulations of Connecticut State Agencies;
Page 8 of 36

R-39 Rev. 02/2012

“Extreme high-gloss coating” means a coating that, when tested by American Society for Testing 

Material Test Method D523-08, Standard Test Method for Specular Gloss, shows a reflectance of 75 or 

more on a 60 degree meter;

“Extreme performance coating” means a coating used on a metal surface where the coated surface is, in 

its intended use, subject to one of the following conditions:

(A) Chronic exposure to corrosive, caustic or acidic agents, chemicals, chemical fumes, 

chemical mixtures or solution,

(B) Repeated exposure to temperatures in excess of 250°F, or

(C) Repeated heavy abrasion, including mechanical wear and repeated scrubbing with 

industrial grade solvents, cleaners or scouring agents;

“Fire-resistant interior coating” means, for civilian aircraft, fire-resistant interior coatings used on 

passenger cabin interior parts that are subject to Federal Aviation Administration fireworthiness 

requirements. For military aircraft, fire-resistant interior coatings are used on parts that are subject to the 

flammability requirements of MIL-STD-1630A and MIL-A-87721. For space applications, “fire-resistant 

interior coating” means a coating subject to the flammability requirements of SE-R-0006 and SSP 30233;

“Flexible primer” means a primer with elastomeric qualities that provides a compatible, flexible substrate 

over bonded sheet rubber and rubber-type coatings;

“Flight test coating” means a coating applied to aircraft other than missiles or single-use aircraft prior to 

flight testing to protect the aircraft from corrosion and to provide required marking during flight test 

evaluation;

“Flow coating” means a non-atomized technique of applying coating to a substrate using a fluid nozzle in 

a fan pattern with no air supplied to the nozzle;

“Fog coat” means a coating that is applied to a plastic part at a thickness of no more than 0.5 mils of 

coating solids for the purpose of color matching without masking a molded-in texture;

“Fuel tank adhesive” means an adhesive that must be compatible with fuel tank coatings and is used to 

bond components exposed to fuel;

“Fuel tank coating” means a coating applied to fuel tank components for the purpose of corrosion or 

bacterial growth inhibition and to assure sealant adhesion in extreme environmental conditions;

“General” means a coating category for a coating that does not meet any other category definition 

provided in this subsection for the specified substrate (i.e., metal part or plastic part);

“General aviation rework facility” means any aerospace facility with the majority of its revenues resulting 

from the reconstruction, repair, maintenance, repainting, conversion or alteration of general aviation 

aerospace vehicles or components;

“Gloss reducer” means a coating that is applied to a plastic part at a thickness of no more than 0.5 mils of 

coating solids solely to reduce the shine of the part;

“Heat-resistant coating” means a coating able to withstand a temperature of at least 400° F during normal 

use;
Page 9 of 36

R-39 Rev. 02/2012

“High-performance architectural coating” means a coating used to protect architectural subsections and 

which meets the requirements of the Architectural Aluminum Manufacturer Association's publication 

number AAMA 2604-05 (Voluntary Specification, Performance Requirements and Test Procedures for 

High Performance Organic Coatings on Aluminum Extrusions and Panels) or 2605-05 (Voluntary 

Specification, Performance Requirements and Test Procedures for Superior Performing Organic Coatings 

on Aluminum Extrusions and Panels);

“High temperature coating” means a coating certified to withstand a temperature of 1000oF for 24 hours;

“HVLP spray application” means to apply a coating using a coating application system that uses lower air 

pressure and higher volume than conventional air atomized spray systems, where the manufacturer has 

represented that the system is HVLP by affixing a permanent label or through representations on the 

packaging or other product literature;

“Insulation covering” means material that is applied to foam insulation to protect the insulation from 

mechanical or environmental damage;

“Intermediate release coating” means a thin coating applied beneath topcoats to assist in removing the 

topcoat in depainting operations and to allow the use of less hazardous depainting methods;

“Lacquer” means a clear or pigmented coating formulated with a nitrocellulose or synthetic resin to dry 

by evaporation without a chemical reaction and that is resoluble in its original solvent;

“Large commercial aircraft” means an aircraft of more than 110,000 pounds, maximum certified take-off 

weight, manufactured for non-military use;

“Mask coating” means thin film coating applied through a template to coat a small portion of a substrate;

“Medical device” means an instrument, apparatus, implement, machine, gadget, appliance, implant, in 

vitro reagent or other similar or related article, including any component, part or accessory, which meets 

one of the following conditions:

(A) Recognized in the official National Formulary or the United States Pharmacopeia or any 

supplement thereto,

(B) Intended for use in the diagnosis of disease or other conditions or in the cure, mitigation, 

treatment or prevention of disease in persons or animals, or

(C) Intended to affect the structure or function of the body of a person or animal and which 

does not achieve its primary intended purposes through chemical action within or on such 

body and which is not dependent upon being metabolized for the achievement of its 

primary intended purposes;

“Metalized epoxy coating” means a coating that contains metallic pigmentation for appearance or added 

protection;

“Metallic coating” means a coating that contains more than five grams of metal particles per liter of 

coating, as applied;

“Miscellaneous metal and plastic parts” means metal and plastic components of products as well as the 

products themselves constructed either entirely or partially from metal or plastic including, but not limited 

to: aerospace vehicles and components, fabricated metal products, molded plastic parts, small and large 

farm machinery, commercial and industrial machinery and equipment, automotive or transportation 

equipment, interior or exterior automotive parts, construction equipment, motor vehicle accessories, 
Page 10 of 36

R-39 Rev. 02/2012

bicycles and sporting goods, toys, recreational vehicles, extruded aluminum structural components, 

railroad cars, lawn and garden equipment, business machines, laboratory and medical equipment, 

electronic equipment, steel drums, metal pipes and small appliances;

“Mold-seal coating” means the initial coating applied to a new mold or a repaired mold to provide a 

smooth surface that, when coated with a mold release coating, prevents products from sticking to the 

mold; 

“Mold release” means a coating applied to a mold surface to prevent the molded piece from sticking to 

the mold as it is removed;

“Motor vehicle” means any self-propelled vehicle, including, but not limited to, cars, trucks, buses, golf 

carts, vans, motorcycles, tanks and armored personnel carriers;

“Motor vehicle bedliner coating” means a multi-component coating applied to a cargo bed after the 

application of a topcoat to provide additional durability and chip resistance;

“Motor vehicle cavity wax” means a coating applied into the cavities of the vehicle primarily for the 

purpose of enhancing corrosion protection;

“Motor vehicle deadener” means a coating applied to selected vehicle surfaces primarily for the purpose 

of reducing the sound of road noise in the passenger compartment;

“Motor vehicle gasket/sealing material” means a fluid applied to coat a gasket or replace and perform the 

same function as a gasket. Automobile and light-duty truck gasket/gasket sealing material includes room 

temperature vulcanization (RTV) seal material;

“Motor vehicle lubricating wax/compound” means a protective lubricating material applied to vehicle 

hubs and hinges;

“Motor vehicle sealer” means a high viscosity material generally, but not always, applied in the paint 

shop after the body has received an electrodeposition primer coating and before the application of 

subsequent coatings (e.g., primer-surfacer). The primary purpose of automobile and light-duty truck 

sealer is to fill body joints completely so that there is no intrusion of water, gases or corrosive materials 

into the passenger area of the body compartment. Such materials are also referred to as sealant, sealant 

primer, or caulk;

“Motor vehicle trunk interior coating” means a coating applied to the trunk interior to provide chip 

protection;

“Motor vehicle underbody coating” means a coating applied to the undercarriage or firewall to prevent 

corrosion or provide chip protection;

“Multi-colored coating” means a coating packaged in a single container and applied in a single coat which 

exhibits more than one color when applied;

“Multi-component coating” means a coating requiring the addition of a separate reactive resin, such as a 

catalyst or hardener, before application to form an acceptable dry film;

“Nonstructural adhesive” means an adhesive that bonds nonload bearing aerospace components in 

noncritical applications and is not covered in any other specialty adhesive categories;

“One-component coating” means a coating that is ready for application as packaged for sale, except for 

the addition of a thinner to reduce the viscosity; 
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“Optical antireflection coating” means a coating with a low reflectance in the infrared and visible 

wavelength ranges that is used for antireflection on or near optical and laser hardware;

“Optical coating” means a coating with a low reflectance in the infrared and visible wavelength range that 

is used on or near optical or laser lenses or hardware;

“Overall control efficiency” means the product of the capture efficiency and the control device efficiency;

“Pan-backing coating” means a coating applied to the surface of pots, pans or other cooking implements 

that are exposed directly to a flame or other heating element; 

“Part marking coating” means coatings or inks used to make permanent or temporary identifying 

markings on materials, components or assemblies;

“Plastic part” means any piece or combination of pieces of which at least one has been formed from one 

or more resins. Such pieces may be solid, porous, flexible or rigid. “Plastic part” does not include a part

made of fiberglass or composite material;

“Powder coating” means any coating applied as a dry, finely divided solid that, when melted and fused, 

adheres to the substrate as a paint film;

“Prefabricated architectural component coating” means a coating applied to prefabricated metal parts and 

products that are to be used as architectural appurtenances or structures and that are detached from the 

structure when coated in a shop environment;

“Pretreatment coating” means a coating, containing at least 0.5 percent acid by weight, applied directly to

a metal or composite surface to provide surface etching, corrosion resistance, adhesion and ease of

stripping;

“Primer” means a coating applied to prevent corrosion, provide protection or provide a surface for 

adhesion of subsequent coatings;

“Radome” means the nonmetallic protective housing for electromagnetic transmitters and receivers such 

as radar or electronic countermeasures;

“Rain erosion-resistant coating” means a coating or coating system used to protect the leading edges of 

parts, such as flaps, stabilizers, radomes or engine inlet nacelles against erosion caused by rain impact 

during flight;

“Related cleaning” means the removal of uncured coatings, coating residue and contaminants from:

(A) Miscellaneous metal and plastic parts prior to the application of coatings,

(B) Miscellaneous metal and plastic parts between coating applications, or

(C) Transfer lines, storage tanks, spray booths and coating application equipment;

“Repair coating” means a coating used to recoat portions of a product that has sustained mechanical 

damage to the coating following normal painting operations; 

“Resin” means any of numerous physically similar polymerized synthetics or chemically modified natural 

materials including thermoplastic materials such as polyvinyl, polystyrene and polyethylene and 

thermosetting materials such as polyesters, epoxies and silicones;
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“Resist coating” means a coating that is applied to a plastic part before metallic plating to prevent 

deposits of metal on portions of the plastic part;

“Rocket motor bonding adhesive” means an adhesive used in rocket motor bonding applications;

“Rocket motor nozzle coating” means a catalyzed epoxy coating system used in elevated temperature 

applications on rocket motor nozzles;

“Roll coating” means a coating method using a machine that applies coating to a substrate by 

continuously transferring coating through a set of oppositely rotating rollers;

“Rubber-based adhesive” means a quick-setting contact cement that provides a strong, yet flexible bond 

between two substrates that may be of dissimilar materials;

“Safety-indicating coating” means a coating that changes in a physical characteristic, such as color, to 

indicate unsafe conditions;

“Scale inhibitor” means a coating that is applied to the surface of a part prior to thermal processing to

inhibit scale formation;

“Screen print ink” means an ink used in screen printing processes during fabrication of decorative 

laminates and decals;

“Sealant” means a material used to prevent the intrusion of water, fuel, air or other liquids or solids from 

certain areas of aerospace vehicles or components;

“Seal coat maskant” means an overcoat applied over a maskant to improve abrasion and chemical 

resistance during production operations;

“Self-priming topcoat” means one or more layers of identical coating formulation of a topcoat that is 

applied directly to an uncoated aerospace vehicle or component for corrosion prevention, environmental 

protection or functional fluid resistance;

“Shock-free coating” means a coating applied to electrical components to protect the user from electric 

shock and that provides for low capacitance and high resistance and resists breaking down under high 

voltage; 

“Silicone insulation material” means an insulating material that is not sacrificial and that is applied to 

exterior metal surfaces for protection from high temperatures caused by atmospheric friction or engine 

exhaust;

“Silicone-release coating” means any coating that contains silicone resin and is intended to prevent food 

from sticking to metal surfaces such as baking pans;

“Solar-absorbent coating” means a coating that has as its primary purpose the absorption of solar 

radiation;

“Solid-film lubricant” means a very thin coating consisting of a binder system containing as its chief 

pigment material one or more of molybdenum disulfide, graphite, polytetrafluoroethylene or other solids 

that act as a dry lubricant between faying surfaces;

“Space vehicle” means a man-made device, either manned or unmanned, designed for operation beyond 

earth's atmosphere, including, but not limited to, integral equipment such as models, mock-ups, 
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prototypes, molds, jigs, tooling, hardware jackets and test coupons, including auxiliary equipment 

associated with test, transport and storage, which through contamination can compromise the space 

vehicle performance;

“Specialty coating” means a coating that, even though it meets the definition of a primer, topcoat or selfpriming topcoat, has additional performance criteria beyond those of primers, topcoats and self-priming 

topcoats for specific applications. Such performance criteria may include, but are not limited to,

temperature or fire resistance, substrate compatibility, antireflection, temporary protection or marking, 

sealing, adhesion or enhanced corrosion protection;

“Specialized function coating” means a coating that is limited in application, characterized by low volume 

usage and is not able to be categorized as any other coating in Table 20(s)-6a;

“Stencil coating” means an ink or a coating that is rolled or brushed onto a template or stamp to add 

identifying letters or numbers to metal parts or products; 

“Structural autoclavable adhesive” means an adhesive used to bond load-carrying aerospace components 

that is cured by heat and pressure in an autoclave;

“Structural nonautoclavable adhesive” means an adhesive cured under ambient conditions that is used to 

bond load-carrying aerospace components or other critical functions, such as nonstructural bonding in the 

proximity of engines;

“Temporary protective coating” means a coating applied to provide scratch or corrosion protection during 

manufacturing, storage or transportation. “Temporary protective coating” does not include any coating 

that protects against strong acid or alkaline solutions;

“Texture coat” means a coating that is applied to a plastic part which, in its finished form, consists of 

discrete raised spots of the coating;

“Textured finish” means a rough surface produced by spraying and splattering large drops of coating onto 

a previously applied coating;

“Thermal control coating” means a coating formulated with specific thermal conductive or radiative 

properties to permit temperature control of the substrate;

“Topcoat” means the final coating applied in a process of applying two or more coatings; 

“Touch-up coating” means a coating used to cover minor coating imperfections appearing after the main 

coating operation; 

"Transfer efficiency" means the portion of coating solids that adheres to the metal or plastic surface 

during the application process, expressed as a percentage of the total volume of coating solids delivered 

by the applicator;

“Translucent coating” means a coating which contains binders and pigment and is formulated to form a 

colored, but not opaque, film;

“Vacuum-metalizing coating” means the undercoat applied to a substrate on which the metal is deposited 

prior to a vacuum-metalizing process or the overcoat applied directly to the metal film after a vacuummetalizing process; 

“Vacuum metalizing process” means the process of evaporating metals inside a vacuum chamber 

and depositing them on a substrate to achieve a uniform metalized layer;
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“Wet fastener installation coating” means a primer or sealant applied by dipping, brushing or daubing to 

fasteners that are installed before the coating is cured; and

“Wing coating” means a corrosion-resistant topcoat that withstands the flexing of aircraft wings and 

rotary wings.

(2) Applicability. 

(A) Except as provided in subdivision (7) of this subsection, the provisions of this subsection 

apply to the owner or operator of any:

(i) Coating unit subject at any time to the provisions of subsection (s) of this section 

that was in effect prior to the effective date of this regulation, or

(ii) Miscellaneous metal and plastic parts coating unit for which the owner or 

operator purchases for use at the premises 855 gallons or more of coatings and 

cleaning solvents in the aggregate per rolling 12-month period. 

(B) Any owner or operator of a miscellaneous metal or plastic parts coating unit who does 

not meet the applicability requirements provided in subparagraph (A) of this subdivision

shall maintain either material purchase or actual usage records to verify that this 

subsection does not apply to such owner or operator. 

(C) An owner or operator subject to this subsection shall: 

(i) For a miscellaneous metal and plastic parts coating unit that is in operation prior 

to or on the effective date of this regulation, comply with the requirements of this 

subsection no later than January 1, 2013, or

(ii) For a miscellaneous metal and plastic parts coating unit that commences 

operation after January 1, 2013, comply with the requirements of this subsection 

upon commencing operation.

(D) Any owner or operator subject to this subsection shall remain subject to this subsection.

(3) Except as provided in subdivision (7) of this subsection, on and after January 1, 2013, no owner 

or operator shall apply any coating, inclusive of any VOC-containing material added to the original 

coating supplied by the manufacturer, unless the owner or operator controls emissions of VOCs in 

accordance with subparagraph (A), (B), (C) or (D) of this subdivision. If more than one emission limit or 

emission rate applies in a particular situation, then the least restrictive limit or emission rate shall apply. 

An owner or operator shall control the emission of VOCs as follows: 

(A) Use only coatings that have an as applied VOC content no greater than the applicable 

level in Table 20(s)-1, 20(s)-2, 20(s)-3, 20(s)-4, 20(s)-5, 20(s)-6a or 20(s)-6b;

(B) For a coating unit, use a combination of low-VOC coatings and add-on air pollution 

control equipment to achieve a VOC emission rate no greater than the applicable level in 

Table 20(s)-7, 20(s)-8, 20(s)-9, or 20(s)-10;

(C) Install, operate and maintain according to the manufacturer’s recommendations air 

pollution control equipment with an overall control efficiency of at least 90%; or
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(D) Achieve a level of control that is equivalent to subparagraph (A), (B) or (C) of this 

subdivision, as requested from and approved by the commissioner, in accordance with 

subsection (cc) of this section.

(E) An owner or operator controlling emissions as provided in subparagraph (A), (B), (C) or 

(D) of this subdivision is exempt from any obligation to comply with subsection (bb) of 

this section. 

(F) The requirements of subparagraphs (A), (B), (C) or (D) of this subdivision shall not apply

to a coating upon request to and approval by the commissioner and the Administrator. 

Any request for approval shall be made in writing and shall include a description of the

noncompliant coating and its VOC content, an explanation of why the noncompliant 

coating is necessary, the aggregate amount in gallons or pounds of noncompliant coating 

use anticipated in a 12-month period and the frequency of use of the noncompliant 

coating.

(4) Application methods. Except as provided in subdivision (7) of this subsection, an owner or 

operator shall not apply a VOC-containing coating to a miscellaneous metal and plastic part unless the 

coating is applied by one of the methods identified in subparagraphs (A) through (I) of this subdivision

using equipment operated in accordance with the specifications of the equipment manufacturer:

(A) Electrostatic application; 

(B) Flow coating;

(C) Dip coating;

(D) Roll coating;

(E) HVLP spray application;

(F) Airless spray application;

(G) Air-assisted airless spray application;

(H) Hand application; or

(I) Any other coating application method capable of achieving a transfer efficiency 

equivalent to or better than that provided by HVLP spray application. Any owner or 

operator using an application method pursuant to this subparagraph shall maintain 

records demonstrating the transfer efficiency achieved.

(5) Work practices. Each owner or operator shall use the following work practices:

(A) New and used VOC-containing coating, diluent or cleaning solvent, including a coating 

mixed on the premises, shall be stored in a nonabsorbent, non-leaking container. Such a 

container shall be kept closed at all times except when the container is being filled, 

emptied or is otherwise actively in use; 

(B) Spills and leaks of VOC-containing coating, diluent or cleaning solvent shall be 

minimized. Any leaked or spilled VOC-containing coating, diluent or cleaning solvent 

shall be absorbed and removed immediately;
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(C) Absorbent applicators, such as cloth and paper, which are moistened with a VOCcontaining coating or solvent, shall be stored in a closed, nonabsorbent, non-leaking 

container for disposal or recycling; and

(D) VOC-containing coating, diluent and cleaning solvent shall be conveyed from one 

location to another in a closed container or pipe. 

(6) Notwithstanding the requirements of this subsection, an owner or operator complying with this 

subsection by operating under a valid permit or order issued pursuant to subsection (cc)(2) or (cc)(3) of 

this section shall continue to operate according to the terms of such permit or order. 

(7) Exemptions and exceptions. 

(A) The requirements of this subsection shall not apply to any of the following activities, and 

the VOC emissions resulting from the following activities shall not be included in 

determinations pursuant to subdivisions (2) and (7)(G) of this subsection: 

(i) Coating and cleaning subject to one of the following subsections of this section: 

(l) through (r) and (hh) through (kk),

(ii) Coating applied in an automotive refinishing operation and related cleaning,

(iii) Coating and associated surface preparation and cleanup subject to section 22a174-41 of the Regulations of Connecticut State Agencies,

(iv) Coating applied to test materials, test panels and coupons in research and 

development, quality control or performance testing, 

(v) Coating applied in a shipbuilding and repair operation, provided that the 

operation is subject to 40 CFR 63 Subpart II,

(vi) Coating applied to space vehicles and related cleaning,

(vii) Coating applied to antique aerospace vehicles and related cleaning,

(viii) Coating applied with a hand-held aerosol can,

(ix) Adhesive, sealant, adhesive primer or sealant primer regulated by section 22a174-44 of the Regulations of Connecticut State Agencies, 

(x) Quality control or inspection dyes applied to metal parts, 

(xi) Use of coatings containing VOC at concentrations less than 1.0 percent by 

weight,

(xii) Use of cleaning solvents containing VOC at concentrations less than 5.0 percent 

by weight, or

(xiii) Maintenance coating and related cleaning of fixtures, equipment and components 

that are not products manufactured by the facility or products coated on a 

contract basis.

(B) The requirements of subdivisions (3) and (4) of this subsection shall not apply to the 

application of any of the following coatings to metal parts: 
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(i) Stencil coating,

(ii) Safety-indicating coating,

(iii) Solid-film lubricant,

(iv) Electric-insulating and thermal-conducting coating,

(v) Magnetic data storage disk coating,

(vi) Plastic extruded onto metal parts to form a coating, or

(vii) Powder coating. 

(C) The requirements of subdivision (3) of this subsection shall not apply to the application 

of any of the following coatings to plastic parts: 

(i) Touch-up and repair coating,

(ii) Stencil coating applied on a clear or transparent substrate,

(iii) Clear or translucent coating,

(iv) Reflective coating applied to a highway cone,

(v) Mask coating less than 0.5 millimeters thick applied to an area less than 25 

square inches,

(vi) EMI/RFI shield coating,

(vii) Any heparin-benzalkonium chloride (HBAC)-containing coating applied to a 

medical device, provided that the total of all HBAC-containing coatings used at a 

facility does not exceed 100 gallons per year, or 

(viii) Powder coating.

(D) The requirements of subdivision (3) of this subsection shall not apply to the application 

of any of the following coatings to automotive-transportation and business machine parts:

(i) Vacuum metalizing coating,

(ii) Gloss reducer,

(iii) Texture coat,

(iv) Adhesion bonding primer,

(v) Electrostatic preparation coating,

(vi) Resist coating, 

(vii) Stencil coating, or
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(viii) Powder coating.

(E) The requirements of subdivisions (3) and (4) of this subsection shall not apply to the 

application of any of the following specialty coatings to an aerospace vehicle or 

component:

(i) Touch-up coating, or

(ii) Aerospace coating that the United States Department of Defense has designated

as classified information in accordance with 32 CFR 2001.

(F) The requirements of subdivision (4) of this subsection shall not apply to the following 

activities: 

(i) Application of touch-up and repair coating to metal parts,

(ii) Application of textured finish to metal parts,

(iii) Application of powder coating to:

(I) Plastic parts,

(II) Automotive-transportation plastic parts, or

(III) Business machine plastic parts,

(iv) Airbrush application of coating to metal or plastic parts using no more than five 

gallons of coating per year,

(v) Use of air pollution control equipment to comply with subdivision (3) of this 

subsection, or

(vi) Application of specialty coatings listed in Table 20(s)-6a of this subsection.

(G) An owner or operator with total potential VOC emissions from all miscellaneous metal 

and plastic parts coating, including emissions from related cleaning, limited by permit or 

order of the commissioner to 1,666 pounds or less in any calendar month, shall not be 

subject to the requirements of subdivision (3) of this subsection, provided that the owner 

or operator operates in compliance with such permit or order. 

(H) An owner or operator may use, in the aggregate, in any 12 consecutive months no more 

than 55 gallons of miscellaneous metal or plastic parts coating or coatings that exceed the 

VOC content limits or emission limits of subdivision (3) of this subsection provided the 

owner or operator maintains records of non-compliant coating use. 

(I) An owner or operator operating pursuant to an exemption or exception set out in this 

subdivision shall maintain records sufficient to verify the applicability of the exemption 

or exception. 

(8) Records. 

(A) An owner or operator shall maintain records of information sufficient to determine 

compliance with the applicable requirements of this subsection, including, at a minimum, 

the following information for each calendar month:
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(i) Name and description of each coating and cleaning solvent,

(ii) VOC content of each coating and diluent, as applied, and the associated 

calculations,

(iii) VOC content of each coating or cleaning solvent, as supplied,

(iv) The amount of each coating and cleaning solvent:

(I) Purchased, or

(II) Used,

(v) A Material Safety Data Sheet, Environmental Data Sheet, Certified Product Data 

Sheet, or an equivalent data sheet for each coating and cleaning solvent,

(vi) Documentation of control device efficiency and capture efficiency, if applicable, 

using an applicable EPA reference method or alternate method as approved by 

the commissioner and the Administrator, and

(vii) Date and type of maintenance performed on air pollution control equipment, if 

applicable.

(B) All records made pursuant to this subdivision shall be:

(i) Made available to the commissioner to inspect and copy upon request, and

(ii) Maintained for five years from the date such record is created.

(9) Compliance procedures.

(A) The VOC content limits of Table 20(s)-1, 20(s)-2, 20(s)-3, 20(s)-4, 20(s)-5, 20(s)-6a or 

20(s)-6b apply to the volume of coating as applied, determined using the following 

equation:

VOC Content = (Ws - Ww-Wes)/(Vm - Vw – Ves)

Where: Ws = weight of volatile compounds in grams

Ww = weight of water in grams

Wes = weight of exempt compounds in grams

Vm = volume of coating in liters

Vw = volume of water in liters

Ves = volume of exempt compounds in liters

(B) The VOC emission rate limits of Table 20(s)-7, 20(s)-8, 20(s)-9, or 20(s)-10 apply to the 

mass of VOC emitted per volume of coating solids, as applied. 

(C) To determine the properties of a coating or components thereof in order to perform the 

calculations required pursuant to subparagraph (A) of this subdivision or to verify 

calculations based on the manufacturer’s formulation data, the VOC and solids content of 

all coatings shall be determined using 40 CFR 60, Appendix A, Reference Method 24 or 

an equivalent method. In the case of a dispute, the VOC content determined using 

Reference Method 24 shall control, unless a person is able to demonstrate to the 
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satisfaction of the commissioner and the Administrator that the manufacturer’s 

formulation data are correct. 

(D) For red, yellow or black automotive coatings, except touch-up and repair coatings, the 

applicable VOC content limit or emission rate shall be the limit of Table 20(s)-3 or 20(s)-

9, as applicable, multiplied by 1.15.

(E) Where a VOC content limit or emissions rate is provided in metric units and equivalent 

English units, the limit or rate in metric units defines the standard. The English units are 

provided for information only.

(F) A miscellaneous metal or plastic parts coating shall be defined and categorized based on 

the manufacturer’s representations as set out on the container or label or in information 

provided by the manufacturer of such a miscellaneous metal or plastic parts coating.

(10) Limitations on potential to emit.

(A) An owner or operator may submit a request to the commissioner for an order or permit to 

limit potential emissions from all miscellaneous metal and plastic parts coating at the 

premises to a monthly limit of 1,666 pounds of VOC; or

(B) An owner or operator issued a permit or order prior to January 1, 2013 pursuant to former 

section 22a-174-20(s)(7) of the Regulations of Connecticut State Agencies may: 

(i) Continue after January 1, 2013 to conduct miscellaneous metal parts coating in 

compliance with such a permit or order, 

(ii) Submit a request to the commissioner to modify the order or permit to include all 

miscellaneous metal and plastic parts coating at the premises in the monthly limit 

of 1,666 pounds of VOC, or

(iii) Submit a request to the commissioner to revoke the order or permit.

Table 20(s)-1

Metal Parts Coating VOC Content Limits

Coating Category

Air Dried Baked

g VOC/ liter 

coating

lbs VOC/ gal 

coating

g VOC/ liter 

coating

lbs VOC/ gal 

coating

General one-component 340 2.8 280 2.3

General multi-component 340 2.8 280 2.3

Camouflage 420 3.5 420 3.5

Electric-insulating varnish 420 3.5 420 3.5

Etching filler 420 3.5 420 3.5

Extreme high-gloss 420 3.5 360 3.0

Extreme performance 420 3.5 360 3.0

Heat-resistant 420 3.5 360 3.0

High performance 

architectural 

740 6.2 740 6.2

High temperature 420 3.5 420 3.5

Metallic 420 3.5 420 3.5

Mold-seal 420 3.5 420 3.5

Pan backing 420 3.5 420 3.5
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Prefabricated architectural 

multi-component 

420 3.5 280 2.3

Prefabricated architectural 

one-component 

420 3.5 280 2.3

Pretreatment coating 420 3.5 420 3.5

Repair and touch-up 420 3.5 360 3.0

Silicone release 420 3.5 420 3.5

Solar-absorbent 420 3.5 360 3.0

Vacuum-metalizing 420 3.5 420 3.5

Drum coating, new, exterior 340 2.8 340 2.8

Drum coating, new, interior 420 3.5 420 3.5

Drum coating, reconditioned, 

exterior

420 3.5 420 3.5

Drum coating, reconditioned, 

interior 

500 4.2 500 4.2

Table 20(s)-2

Plastic Parts Coating VOC Content Limits 

Coating Category g VOC/liter coating lbs VOC/gal coating

General one-component 280 2.3

General multi-component 420 3.5

Electric dissipating coatings and shock-free 

coating

800 6.7

Extreme performance multi-component 420 3.5

Metallic 420 3.5

Mold-seal 760 6.3

Multi-colored coating 680 5.7

Optical coating 800 6.7

Vacuum-metalizing 800 6.7

Table 20(s)-3

Automotive-Transportation Plastic Parts Coating VOC Content Limits 

Coating Category g VOC/liter coating lbs VOC/gal coating

I. High bake coatings – interior and exterior parts

Flexible primer 540 4.5

Non-flexible primer 420 3.5

Base coat 520 4.3

Clear coat 480 4.0

Non-base coat/clear coat 520 4.3

II. Low bake/air dried coatings – exterior parts

Primer 580 4.8

Base coat 600 5.0

Clearcoat 540 4.5

Non-base coat/clearcoat 600 5.0

III. Low bake/air dried coatings – interior 

parts

600 5.0

IV. Touchup and repair coating 620 5.2
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Table 20(s)-4

Business Machine Plastic Parts Coating VOC Content Limits

Coating Category g VOC/liter coating lbs VOC/gal coating

I. Primers 350 2.9

II. Topcoat 350 2.9

III. Texture coat 350 2.9

IV. Fog coat 260 2.2

V. Touchup and repair 350 2.9

Table 20(s)-5

Motor Vehicle Materials VOC Content Limits

Coating Category g VOC/liter coating lbs VOC/gal coating

Motor vehicle cavity wax 650 5.4

Motor vehicle sealer 650 5.4

Motor vehicle deadener 650 5.4

Motor vehicle gasket/gasket sealing material 200 1.7

Motor vehicle underbody coating 650 5.4

Motor vehicle trunk interior coating 650 5.4

Motor vehicle bedliner coating 200 1.7

Motor vehicle lubricating wax/compound 700 5.8

Table 20(s)-6a

Aerospace Specialty Coating VOC Content Limits

Coating type g VOC/liter coating

Ablative coating 600

Adhesion promoter 890

Adhesive bonding primers:

Cured at 250°F or below 850

Cured above 250°F 1030

Adhesives:

Commercial interior adhesive 760

Cyanoacrylate adhesive 1,020

Fuel tank adhesive 620

Nonstructural adhesive 360

Rocket motor bonding adhesive 890

Rubber-based adhesive 850

Structural autoclavable adhesive 60

Structural nonautoclavable adhesive 850

Aerospace high-temperature coating 850

Antichafe coating 660

Bearing coating 620

Caulking and smoothing compounds 850

Chemical agent-resistant coating 550

Clear coating 720
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Commercial exterior aerodynamic structure primer 650

Compatible substrate primer 780

Corrosion prevention compound 710

Cryogenic flexible primer 645

Cryoprotective coating 600

Dry lubricative material 880

Electric or radiation-effect coating 800

Electrostatic discharge and electromagnetic interference (EMI) 

coating

800

Elevated-temperature Skydrol-resistant commercial primer 740

Epoxy polyamide topcoat 660

Fire-resistant interior coating 800

Flexible primer 640

Flight-test coatings:

Missile or single use aircraft 420

All other 840

Fuel-tank coating 720

Insulation covering 740

Intermediate release coating 750

Lacquer 830

Maskants:

Bonding maskant 1,230

Critical use and line sealer maskant 1,020

Seal coat maskant 1,230

Metallized epoxy coating 740

Mold release 780

Optical anti-reflective coating 750

Part marking coating 850

Pretreatment coating 780

Rain erosion-resistant coating 850

Rocket motor nozzle coating 660

Scale inhibitor 880

Screen print ink 840

Sealants:

Extrudable/rollable/brushable sealant 280

Sprayable sealant 600

Silicone insulation material 850

Solid film lubricant 880

Specialized function coating 890

Temporary protective coating 320

Thermal control coating 800

Wet fastener installation coating 675

Wing coating 850
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Table 20(s)-6b

Aerospace Coating VOC Content Limits

Coating type g VOC/liter coating

Primer – general aviation rework facilities 540

Exterior primer – large commercial aircraft components 650

Exterior primer – fully assembled, large commercial aircraft 650

Primer 350

Topcoat 420

Topcoat – general aviation rework facilities 540

Self-priming topcoat 420

Self-priming topcoat – general aviation rework facilities 540

Type I chemical milling maskant 622

Type II chemical milling maskant 160

Table 20(s)-7

Metal Parts Coating VOC Emission Rate Limits 

Air Dried Baked

Coating Category

g VOC/ 

liter solids

lb VOC/ 

gal solids

g VOC/ 

liter solids

lb VOC/ gal 

solids

General one-component 540 4.52 400 3.35

General multi-component 540 4.52 400 3.35

Camouflage 800 6.67 800 6.67

Electric-insulating varnish 800 6.67 800 6.67

Etching filler 800 6.67 800 6.67

Extreme high-gloss 800 6.67 610 5.06

Extreme performance 800 6.67 610 5.06

Heat-resistant 800 6.67 610 5.06

High performance architectural 4560 38 4560 38

High temperature 800 6.67 800 6.67

Metallic 800 6.67 800 6.67

Mold-seal 800 6.67 800 6.67

Pan backing 800 6.67 800 6.67

Prefabricated architectural multicomponent 800 6.67 400 3.35

Prefabricated architectural onecomponent 800 6.67 400 3.35

Pretreatment coating 800 6.67 800 6.67

Silicone release 800 6.67 800 6.67

Solar-absorbent 800 6.67 610 5.06

Vacuum-metalizing 800 6.67 800 6.67

Drum coating, new, exterior 540 4.52 540 4.52

Drum coating, new, interior 800 6.67 800 6.67

Drum coating, reconditioned, exterior 800 6.67 800 6.67

Drum coating, reconditioned, interior 1170 9.78 1170 9.78
Page 25 of 36

R-39 Rev. 02/2012

Table 20(s)-8

Plastic Parts Coating VOC Emission Rate Limits 

Coating Category g VOC/liter solids lbs VOC/gal solids

General one-component 400 3.35

General multi-component 800 6.67

Electric dissipating coatings and shock-free 

coatings 8960 74.7

Extreme performance multi-component 800 6.67 

Metallic 800 6.67

Mold-seal 5240 43.7

Multi-colored coatings 3040 25.3

Optical coatings 8960 74.7

Vacuum-metalizing 8960 74.7

Table 20(s)-9

Automotive-Transportation Plastic Parts Coating VOC Emission Rate Limits

Coating Category g VOC/liter solids lbs VOC/gal solids

I. High bake coatings – interior and exterior parts

Flexible primer 1390 11.58

Non-flexible primer 800 6.67

Base coat 1240 10.34

Clear coat 1050 8.76

Non-base coat/clear coat 1240 10.34

II. Low bake/air dried coatings – exterior parts

Primer 1660 13.8

Base coat 1870 15.59

Clearcoat 1390 11.58

Non-base coat/clearcoat 1870 15.59

III. Low bake/air dried coatings – interior parts 1870 15.59

IV. Touch-up and repair coating 2130 17.72

Table 20(s)-10

Business Machine Plastic Parts Coating VOC Emission Rate Limits 

Coating Category g VOC/liter solids lbs VOC/gal solids

I. Primers 570 4.80

II. Topcoat 570 4.80

III. Texture coat 570 4.80

IV. Fog coat 380 3.14

V. Touchup and repair 570 4.80
Page 26 of 36

R-39 Rev. 02/2012

Sec. 2. Subdivision (1) of subsection (aa) of section 22a-174-20 of the Regulations of Connecticut 

State Agencies is amended to read as follows:

(aa) Record keeping requirements and test methods.

(1) The owner or “operator” of any premise subject to the provisions of subsections (m) through [(s)] 

(r) inclusive and subsection (v) of section 22a-174-20 shall maintain daily records of all coatings and 

diluents used. Such records shall be kept for each individual machine, operation or coating line. The 

records must contain the information required below.

(A) description of the coating including the coating name and the coating density in pounds 

per gallon;

(B) “volatile organic compound” content by weight;

(C) water and exempt volatile organic compound content by weight;

(D) non-volatile content by volume and by weight;

(E) amount of each coating used in gallons;

(F) total amount of diluent used for each coating in pounds and in gallons.

Sec. 3. Subdivisions (2) and (3) of subsection (cc) of section 22a-174-20 of the Regulations of 

Connecticut State Agencies are amended to read as follows:

[(cc)(2)] (2) The implementation of an alternative emission reduction plan instead of compliance with 

the [“]emissions limitation[”] prescribed in any one of subsections (m) through (v), inclusive, [and] (ee)

or (ff) to (kk), inclusive, of this section [must ] shall be expressly approved by the [“Commissioner”] 

commissioner through the issuance of a permit or an order in accordance with the provisions of section 

22a-174-12 of the Regulations of Connecticut State Agencies and approved by the [“administrator”] 

Administrator in accordance with the provisions of 42 [U.S.C.] USC 7401-7642. After approval, any 

emissions in excess of those established for each emission source under the plan will be a violation of 

these regulations.

[(cc)(3)] (3) Where it can be shown to the satisfaction of the [“Commissioner”] commissioner that an 

emission source cannot be controlled to comply with any one of subsections (m) through (v), inclusive,

[and] (ee) or (ff) to (kk), inclusive, of this section for reasons of technological and economic feasibility, 

the [“Commissioner”] commissioner may by permit or order accept a lesser degree of control upon the 

submission of satisfactory evidence that the [“]stationary source[”] owner has applied [“]Reasonably 

Available Control Technology[”] and has a plan to develop the technologies necessary to comply with 

[the above subsections] the applicable subsection of subsections (m) to (v), inclusive, (ee) or (ff) to (kk), 

inclusive, of this section and such action is approved by the [“administrator”] Administrator in 

accordance with the provisions of 42 [U.S.C.] USC 7401-7642.
Page 27 of 36

R-39 Rev. 02/2012

Sec. 4. Section 22a-174-20(ii)(3)(A) of the Regulations of Connecticut State Agencies is amended to 

read as follows:

(A) The requirements of this subsection shall not apply to the use of cleaning solvent

as follows:

(i) In janitorial cleaning,

(ii) At an aerospace manufacturing and rework operation or a wood furniture coating 

operation in accordance with an order or a permit issued pursuant to sections 22a-174-

32(e) and 22a-174-20(cc) of the Regulations of Connecticut State Agencies,

(iii) To perform general solvent cleaning in accordance with an order issued pursuant to 

section 22a-174-20(ee) of the Regulations of the Connecticut State Agencies,

(iv) At any aerospace manufacturing and rework facility, provided that cleaning solvent is 

used in accordance with the requirements of 40 CFR 63.744, inclusive of exemptions,

(v) As surface preparation or cleanup solvent in accordance with section 22a-174-44 of the 

Regulations of Connecticut State Agencies,

(vi) Where the cleaning solvent is regulated pursuant to section 22a-174-40 of the 

Regulations of Connecticut State Agencies,

(vii) To perform industrial solvent cleaning where such cleaning or cleaning solvent is subject 

to one of the following subsections of this section: (l) through (y), (ff) through (hh), or 

(jj),

(viii) In cleaning, including surface preparation prior to coating, necessary to meet a standard 

or specification issued or approved by the United States Department of Defense, Federal 

Aviation Administration or other federal government entity. Any person claiming 

exemption pursuant to this clause shall maintain records of the standard or specification,

(ix) Associated with research and development,

(x) Associated with quality control or laboratory testing[,] of coatings, inks or adhesives,

(xi) Associated with medical device manufacturing,

(xii) Associated with pharmaceutical manufacturing,

(xiii) That exceeds the applicable limit of subdivision (4)(A) of this subsection where the 

quantity used does not exceed 55 gallons per any twelve-month rolling aggregate. Any 

person claiming exemption pursuant to this clause shall record and maintain monthly 

records sufficient to demonstrate compliance with this exemption, or

(xiv) That exceeds the applicable limit of subdivision (4)(A) of this subsection, if approved by 

the commissioner and the Administrator. Any request for approval shall be made in 

writing to the commissioner and Administrator and shall include a description of the 

cleaning solvent and its VOC content, an explanation of why the cleaning solvent is 

necessary, quantification of the amount of the VOC that will be emitted as a result of the 

use of the noncompliant cleaning solvent and the time period over which the 

noncompliant solvent will be used.
Page 28 of 36

R-39 Rev. 02/2012

Sec. 5. Section 22a-174-20 of the Regulations of Connecticut State Agencies is amended by the 

addition of new subsection (kk), as follows:

(NEW)

(kk) Pleasure craft coatings

(1) Definitions. For the purposes of this section, the following definitions apply:

(A) “Airless spray application” means a coating spray application system using high fluid 

pressure, without compressed air, to atomize the coating; 

(B) “Air-assisted airless spray application” means a coating spray application system using 

fluid pressure to atomize the coating and low pressure air to adjust the shape of the spray 

pattern;

(C) “Antifouling coating” means a coating applied to the underwater portion of a pleasure 

craft to prevent or reduce the attachment of biological organisms;

(D) “Antifouling sealer or tie coat” means a coating applied over biocidal antifouling coating 

for the purpose of preventing release of biocides into the environment or to promote 

adhesion between an antifouling coating and a primer or another antifouling coating;

(E) “As applied” means the composition of coating, excluding water and exempt compounds, 

at the time it is applied to a surface, including any solvent, catalyst or other substance 

added to the coating;

(F) “Capture efficiency” means the ratio of VOC emissions delivered to the control device to 

the total VOC emissions resulting from pleasure craft coating and related cleaning, 

expressed as a percentage;

(G) “Control device efficiency” means the ratio of VOC emissions recovered or destroyed by 

the control device to the total VOC emissions that are introduced into the device, 

expressed as a percentage;

(H) “Electrostatic application” means a method of applying coating particles or coating 

droplets to a grounded surface by electrically charging such particles or droplets;

(I) “Exempt compound” means a carbon compound excluded from the definition of “volatile 

organic compound” as defined in section 22a-174-1 of the Regulations of Connecticut 

State Agencies;

(J) “Extreme high-gloss coating” means a coating that, when tested by American Society for 

Testing Material Test Method D523-08, Standard Test Method for Specular Gloss, shows 

a reflectance of 90 or more on a 60 degree meter;

(K) “Finish primer or surfacer” means a coating applied with a wet film thickness of less than 

10 millimeters prior to the application of a topcoat for purposes of providing corrosion 

resistance, adhesion of subsequent coatings, a moisture barrier or promotion of a uniform 

surface necessary for filling in surface imperfections;

(L) “Flow coating” means a non-atomized technique of applying coating in a fan pattern to a 

substrate using a fluid nozzle with no air supplied to the nozzle;
Page 29 of 36

R-39 Rev. 02/2012

(M) “High build primer or surfacer” means a coating applied with a wet film thickness of 10 

millimeters or more prior to the application of a topcoat for purposes of providing 

corrosion resistance, adhesion of subsequent coatings, a moisture barrier or promotion of 

a uniform surface necessary for filling in surface imperfections;

(N) “High gloss coating” means a coating that, when tested by American Society for Testing 

Material Test Method D523-08, Standard Test Method for Specular Gloss, shows a 

reflectance of 85 or more on a 60 degree meter;

(O) “HVLP spray application” means to apply a coating using a coating application system 

that uses lower air pressure and higher volume than conventional air atomized spray 

systems, where the manufacturer has represented that the system is HVLP by affixing a 

permanent label or through representations on the packaging or other product literature; 

(P) “Overall control efficiency” means the product of the capture efficiency and the control 

device efficiency;

(Q) “Pleasure craft” means any marine or freshwater vessel manufactured or operated 

primarily for recreational purposes;

(R) “Pleasure craft coating” means any marine coating, except unsaturated polyester resin 

(fiberglass), applied to a pleasure craft or to parts and components of a pleasure craft; 

(S) “Pretreatment wash primer” means a coating, containing at least 0.1 percent acid by 

weight and no more than 25 percent solids by weight, that is used to provide surface 

etching and is applied directly to fiberglass and metal surfaces to provide corrosion 

resistance and adhesion of subsequent coatings; 

(T) “Related cleaning” means the removal of uncured coatings, coating residue, and 

contaminants from:

(i) Pleasure craft or parts and components of pleasure craft prior to the application 

of coatings,

(ii) Pleasure craft or parts and components of pleasure craft between coating 

applications, or

(iii) Transfer lines, storage tanks, spray booths, and coating application equipment; 

and

(U) "Transfer efficiency" means the portion of coating solids that adheres to the pleasure craft 

surface during the application process, expressed as a percentage of the total volume of 

coating solids delivered by the applicator.

(2) Applicability. 

(A) Except as provided in subdivision (3) of this subsection, the provisions of this subsection 

apply to the owner or operator of any marina, boat yard, or other premises where pleasure 

craft coating is applied for commercial purposes at the direction of such owner or 

operator, if:

(i) Such owner or operator was subject to subsection (s) of this section prior to 

January 1, 2013, or
Page 30 of 36

R-39 Rev. 02/2012

(ii) Such owner or operator purchases for use in all pleasure craft coating and related 

cleaning at the premises 855 gallons or more of coatings and cleaning solvents in 

aggregate per rolling 12-month period; 

(B) An owner or operator subject to this subsection shall: 

(i) For a source operating prior to January 1, 2013, comply with the requirements of 

this subsection no later than January 1, 2013, or

(ii) For a source that commences operation after January 1, 2013, comply with the 

requirements of this subsection upon commencing operation; and

(C) Any owner or operator subject to this subsection shall remain subject to this subsection.

(D) An owner or operator of any marina, boat yard, or other premises where pleasure craft 

coating is applied for commercial purposes who does not meet the applicability 

thresholds of subparagraph (A) of this subdivision shall maintain either material purchase 

or actual usage records to verify that this subsection does not apply to such owner or 

operator. 

(3) Exemptions and exceptions. 

(A) The requirements of this subsection shall not apply to any of the following activities, and 

the VOC emissions resulting from the following activities shall not be included in 

determinations pursuant to subdivision (2) or (4)(E) of this subsection: 

(i) Coating and cleaning subject to one of the following subsections of this section: 

(l) through (s) and (hh) through (jj),

(ii) Coating and associated surface preparation and cleanup subject to section 22a174-41 of the Regulations of Connecticut State Agencies, 

(iii) Coating applied with a hand-held aerosol can,

(iv) Application of adhesive, sealant, adhesive primer or sealant primer regulated by 

section 22a-174-44 of the Regulations of Connecticut State Agencies, 

(v) Coating applied to test materials, test panels and coupons in research and 

development, quality control or performance testing,

(vi) Use of coatings containing VOC at concentrations less than 1.0 percent by 

weight, or

(vii) Use of cleaning solvents containing VOC at concentrations less than 5.0 

percent by weight.

(B) An owner or operator operating pursuant to an exception or exemption provided in 

subparagraph (A) of this subdivision shall maintain records sufficient to verify the 

applicability of the exception or exemption. 

(C) An owner or operator may use in aggregate in any 12 consecutive months no more than 

55 gallons of pleasure craft coatings that exceed the VOC content limits or emission 

limits of subdivision (4) of this subsection. 
Page 31 of 36

R-39 Rev. 02/2012

(4) On and after January 1, 2013, no owner or operator of a pleasure craft coating operation shall 

apply any coating, inclusive of any VOC-containing material added to the original coating supplied by the 

manufacturer, unless the owner or operator controls emissions of VOCs in accordance with subparagraph 

(A), (B), (C), (D) or (E) of this subdivision. If more than one emission limit or emission rate applies in a 

particular situation, then the least restrictive limit or rate shall apply. An owner or operator shall:

(A) Use only coatings that have an as applied VOC content no greater than the applicable 

level in Table 20(kk)-1;

(B) Use a combination of low-VOC coatings and add-on air pollution control equipment to 

achieve a VOC emission rate no greater than the applicable level in Table 20(kk)-2;

(C) Install, operate and maintain according to the manufacturer’s recommendations air 

pollution control equipment with an overall control efficiency of at least 90%;

(D) Use an alternative means, achieving a level of control equivalent to subparagraph (A), 

(B) or (C) of this subdivision, as requested from and approved by the commissioner, in 

accordance with subsection (cc) of this section; or

(E) Limit the total potential VOC emissions from all pleasure craft coating operations and 

related cleaning by permit or order of the commissioner to 1,666 pounds or less in any 

calendar month.

(5) Application methods. Except as provided in subdivision (3) of this subsection, an owner or 

operator shall not apply a VOC-containing coating to a pleasure craft or to a part or component of a 

pleasure craft unless the coating is applied by one of the methods identified in subparagraphs (A) through 

(F) of this subdivision using equipment operated in accordance with the specifications of the equipment 

manufacturer:

(A) Electrostatic application; 

(B) HVLP spray application;

(C) Airless spray application;

(D) Air-assisted airless spray application;

(E) Hand application; or

(F) Any other coating application method capable of achieving a transfer efficiency 

equivalent to or better than that provided by HVLP spray application. Any coating 

operation using an application method pursuant to this subparagraph shall maintain 

records demonstrating the transfer efficiency achieved.

(G) The requirements of this subdivision shall not apply to the application of an extreme high 

gloss coating. 

(6) Work practices. Each owner or operator shall use the following work practices:

(A) New and used VOC-containing coating, diluent or cleaning solvent, including a coating 

mixed on the premises, shall be stored in a nonabsorbent, non-leaking container. Such a 

container shall be kept closed at all times except when the container is being filled, 

emptied or is otherwise actively in use; 
Page 32 of 36

R-39 Rev. 02/2012

(B) Spills and leaks of VOC-containing coating, diluent or cleaning solvent shall be 

minimized. Any leaked or spilled VOC-containing coating, diluent or cleaning solvent 

shall be contained, absorbed and removed immediately;

(C) Absorbent applicators, such as cloth and paper, which are moistened with a VOCcontaining coating or solvent, shall be stored in a closed, nonabsorbent, non-leaking 

container for disposal or recycling; and

(D) VOC-containing coating, diluent and cleaning solvent shall be conveyed from one 

location to another in a closed container or pipe.

(7) Records. 

(A) Except as provided in subparagraphs (B) and (C), an owner or operator shall maintain 

records of information sufficient to determine compliance with the applicable 

requirements of this subsection, including, at a minimum, the following information for 

each calendar month:

(i) Name and description of each coating and cleaning solvent,

(ii) VOC content of each coating and diluent, as applied, and the associated 

calculations,

(iii) VOC content of each coating or cleaning solvent, as supplied,

(iv) The amount of each coating and cleaning solvent:

(I) Purchased, or

(II) Used,

(v) A Material Safety Data Sheet, Environmental Data Sheet, Certified Product Data 

Sheet, or an equivalent data sheet for each coating and cleaning solvent,

(vi) Documentation of control device efficiency and capture efficiency, if applicable, 

using an applicable EPA reference method or alternate method as approved by 

the commissioner and the Administrator, and

(vii) Date and type of maintenance performed on air pollution control equipment, if 

applicable.

(B) All records made pursuant to this subdivision shall be:

(i) Made available to the commissioner to inspect and copy upon request, and

(ii) Maintained for five years from the date such record is created.

(8) Compliance procedures.

(A) The VOC content limits of Table 20(kk)-1 apply to the volume of coating as applied, 

determined using the following equation:

VOC Content = (Ws - Ww-Wes)/(Vm - Vw – Ves)
Page 33 of 36

R-39 Rev. 02/2012

Where: Ws = weight of volatile compounds in grams

Ww = weight of water in grams

Wes = weight of exempt compounds in grams

Vm = volume of coating in liters

Vw = volume of water in liters

Ves = volume of exempt compounds in liters

(B) The VOC emission rate limits of Table 20(kk)-2 apply to the mass of VOC emitted per 

volume of coating solids, as applied. 

(C) To determine the properties of a coating or components thereof in order to perform the 

calculations required pursuant to subparagraph (A) of this subdivision or to verify 

calculations based on the manufacturer’s formulation data, the VOC and solids content of 

all coatings shall be determined using 40 CFR 60, Appendix A, Reference Method 24 or 

an equivalent method. In the case of a dispute, the VOC content determined using 

Reference Method 24 shall control, unless a person is able to demonstrate to the 

satisfaction of the commissioner and the Administrator that the manufacturer’s 

formulation data are correct. 

(D) Where a VOC content limit or emissions rate is provided in metric units and equivalent 

English units, the limit or rate in metric units defines the standard. The English units are 

provided for information only. 

(E) A pleasure craft coating shall be defined and categorized based on the manufacturer’s 

representations as set out on the container or label or in information provided by the 

manufacturer of such a pleasure craft coating.

Table 20(kk)-1

Pleasure Craft Coating VOC Content Limits

Coating Category g VOC/liter coating lbs VOC/gal coating

Extreme high-gloss coating 600 5.0

High gloss coating 420 3.5

Pretreatment wash primer 780 6.5

Finish primer or surfacer Effective until 

December 31, 2015: 600

Effective January 1, 

2016: 420

Effective until 

December 31, 2015: 5.0

Effective January 1, 

2016: 3.5

High build primer or surfacer 340 2.8

Antifouling coating – aluminum substrate 560 4.7

Antifouling coating – all other substrates 400 3.3

Antifouling sealant or tie coat 420 3.5

All other pleasure craft surface coatings for 

metal or plastic

420 3.5
Page 34 of 36

R-39 Rev. 02/2012

Table 20(kk)-2

Pleasure Craft Surface Coating VOC Emission Rate Limits

Coating Category g VOC/liter solids lbs VOC/gal solids

Extreme high-gloss coating 1100 9.2

High gloss coating 800 6.7

Pretreatment wash primer 6670 55.6

Finish primer or surfacer Effective until 

December 31, 2015: 

1870

Effective January 1, 

2016: 800

Effective until 

December 31, 2015: 

15.59 

Effective January 1, 

2016: 6.7

High build primer or surfacer 550 4.6

Antifouling coating – aluminum substrate 1530 12.8

Antifouling coating – all other substrates 764 6.4 

Antifouling sealer or tie coat 800 6.7

All other pleasure craft surface coatings for metal or 

plastic 

800 6.7

Statement of purpose

The main purpose of this proposal is to enhance existing and add new requirements to control volatile 

organic compound (VOC) emissions from two types of surface coating operations. VOC emissions are a 

precursor to ground-level ozone, a harmful air pollutant. The U.S. Environmental Protection Agency 

(EPA) has designated the entire state as nonattainment for the 2008 ozone national ambient air quality 

standard (NAAQS) and has initiated the statutorily required review of the NAAQS to be completed in 

2013. The proposed limitations on VOC emissions will assist Connecticut to attain and maintain the 

federal ozone NAAQS. 

The Department of Energy and Environmental Protection (DEEP) currently regulates VOC emissions 

from metal parts coating under section 22a-174-20 of the Regulations of Connecticut State Agencies 

(RCSA). In response to EPA guidance, DEEP is proposing to add more stringent VOC control 

requirements for metal parts and to broaden the applicability to include coating of plastic parts. (Section 

1)

Also in accord with EPA guidance, DEEP is proposing new requirements for addition to RCSA section 

22a-174-20 to limit VOC emissions from pleasure craft coating. Owners of marinas and boat yards that 

coat pleasure craft will be required to meet the VOC content limits for coatings and keep records of 

coatings and solvents purchased. (Section 5) 

The requirements for both miscellaneous parts coating and pleasure craft coating include VOC content 

limits for coatings applied; work practices that limit evaporation and waste of coatings and solvents; 

coating application methods; and record keeping requirements. 

Elements of the proposal aside from the parts and pleasure craft coating are minor revisions to address the 

interaction of the revised and new requirements with other subsections of RCSA section 22a-174-20. 

Such revisions are as follows:

Removing redundant record keeping requirements for owners and operators of miscellaneous 

metal and plastic parts coating facilities (Section 2);

Removing an artificial distinction between the use of permits and orders as the enforceable 

mechanisms for alternative emissions control scenarios for sources of volatile organic compound 

emissions (Section 3); and 

Making a minor clarification to the industrial solvent cleaning requirements of subsection (ii) of 

RCSA section 22a-174-20. (Section 4)
R-39 Roy 02/2010

(Certification Page)

Be it known that the foregoing (checkon__~) [] Regulations [] Emergency Regulations

are (check afl that apply) [] Adopted [] Amended as hereinabove stated [~ Repealed

by the aforesaid agency pursuant to section(s) _22a%174__ of the Genera[ Statutes and/or Public

Act number(s) ,

(If applicable) after publication of notice of intent in the Connecticut Law Journal on Septel~be~" 27~ 201 I,

(If applicable) and the holding of an advertised public hearing on November 9 20]. 1;

WHEREFORE, the foregoing regulations are hereby (check all that apply)

[] Adopted [] Amended as hereinabove stated [] Repealed

~[~O"J~VE; (check on~q~ge and complele as applicable)

[] When filed with the Secretary of the State

OR [] (insert date) X~_~7~ t~ t/

In Witness [DATE/ /. 81GNEO(Hea~o~Board,/4. g~e~.#y.£~c~ission) OFFICIAL TITLE, DULY AUTHORIZED

APPROVED by the A~Zorney Genial as t~l su#iciency in ac’~ord~nce with CGS Section 4-169, as amended

/" I d "b, I _

Or ~ D~EMED’APPROVED b~m accordaAc~ith CGS Section 4-169, as amended, due to failure to give

notice to he agency~ le ~al insufficiency w#hN thify (30) days of the receipt of the p~osed regulation.

DATE SIGNED (H~ad of Board, Agency or Commission) /OFFICIAL TITLE, DULY AUTHORIZED

(For Regulation Review Committee Use ONLY)

~ Approved ~Rejected without prejudice

~ Approved with technical corrections ~ Disapproved in pad, (Indicate Section Numbers disapproved

only)

[] Deemed approved

pursuant to CGS 4-170(c) as amended

By the Legislative Regulation Review DATE ~- SI~D (Adminislrator, Legislative Regulati~nF~view Committee)

Committee in accordance with CGS

~- 1~)--"~ !~-O ’ D-- Section 4-170, as amended /~/~ "~-~4~’’{r/"~

Two ced.ff~ed cop~es received and f led and one such copy forwarded to the Commss on on Off c al Legal Pub! cat ons n

accordance with CGS Section 4-172, as amended.

DATE SIGNED (Secretary of the State) BY

iNSTRUCTIONS

I. All regulations proposed for adoption, amendment or repeal, except emergency regulations, must be presented

to the Attorney General for his/her determination of legal sufficiency. (See CGS Section 4-!69.)

2. After approval by the Attorney GeneraI, original and eighteen (18) copies of all regulations proposed for adoption,

amendment or repeat must be presented to the standing Legislative Regulation Review Committee for its action.

(See CGS Section 4-170.)

3. Each proposed regulation must be in the form intended for publication and each section must include the

appropriate regulation section number end section heading. (See CGS Section 4-172.)

4. New language added to an existing regulation must be in underlininq or CAPITAL LETTERS, as determined by

the Regulation Review Committee. (See CGS 4-t70(b).)
R-39 Rev 02/20t2

1) I hereby certify that the above (check on~e) [~ Regulations [-~ Emergency Regulations

2) are (chock aft that apply) [~ adopted ~ amended [~] repealed by this agency

pursuant to the following authority(ies): (complete all that apply)

a. Connecticut General Statutes section(s) 22a-f74

b. Public Act Number(s)

(Provide public act number(s) if the act has not yet been codified in the Connecticut General Statutes.)

3) And I further certify that notice of intent to adopt, amend or repeal said regulations

was published in the Connecticut Law Journal on 27 September 2011.;

(Insert date of notice publication if publication was required by CGS Section 4-158.)

4) And that a public hearing regarding the proposed regulations was held on 9 Nov.

201_~1;

(insert date(s) of public hearing(s) held pursuant to CGS Section 4-168(a)(7), if any, or pursuant to other applicable

statute.)

5) And that said regulations are EFFECTIVE (check on~e, and complete as applicable)

~ When filed with the Secretary of the State

OR [] on (ieae, te).

DATE ~~c/~ or C£~ission) I OFFICIAL TITLE, DULY AUTHORIZED

APPROVED by the A[~~nce with ~G~ection 4-169, as amended

DAT~ ,

(For Regulation Review Committee Use ONL Y) ~,"

~ :~: :-

[~ Approved [] Rejected without prejudice ~: :;-~

pproved with technical corrections [] Disapproved in part (Indicate Section Numbers disapp.~ed ~, :.~r

only)

[] Deemed approved pursuant to CGS 4-170(c) as amended

Committee in accordance with CGS

Section 4-170, as amended l<.m~

Two certified copies received and filed and on& such c(~py forwarded to the Commission on Official

Legal Publications in accordance with CGS Section 4-172, as amended.

(For Secretary of State Use ONLY)
Attachment B

Public Notice of Hearing
Page 2B CONNECTICUT LAW JOURNAL September.27, 2011

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION

Notice of Iutent to Amend the Regulations of Connecticut State Agencies

and to Revise the State Implementation Plan for Air Quality

The Commissioner of Energy and Environmental Protection hereby gives notice

of a public hearing as part of a proceeding to amend section 22a-174-20(s) of the

Regulations of Connecticut State Agencies (RCSA) to establish new and enhance

existing reasonably available control technology (RACT) requirements for miscellaneous metal and plastic parts coating activities. EPA established a new RACT level
September 27, 2011 CONNECTICUT LAW JOURNAL Page 3B

of control for miscellaneous metal and plastic parts coating in contro! techniques

guideline (CTG) issued in 2008 [73 FR 58481].

This proposal amends RCSA section 22a-174-20(s) to update existing requiremerits for metal parts coating operations with lower volatile organic compound

(VOC) content requirements for coatings and work practices designed to reduce

VOC emissions. The proposal also adds new requirements, including VOC content

limits and work practices, applicable to plastic p~s coating operations.

The volatile organic compound (VOC) reductions associated with the RACT

update portion of this proposal will assist Connecticut to attain and maintain the

federal ozone nationa! ambient air quality standards (NAAQS) and serve as directionaily correct measures with respect to Connecticut’s attainment and maintenance of

the fine particulate matter NAAQS. Once adopted, this proposal will be submitted

to the U.S. Environmental Protection Agency (EPA) for review and approval as a

revision to the State Implementation Plan for air quality.

All interested persons are invited to submit comment to the Department of Energy

and Environmental Protection (DEEP), Bureau of Air Management, Engineering &

Enforcement Division, 79oEIm Street, Hartford, Connecticut 06106-5127. All comments should be directed to the attention of Robin Baena and must be received by

5:00 PM on 9 November 2011. Comments may be submitted by post, facsimile to

(860) 424-4064 or by electronic mai! to ~.

In addition to accepting written comments, DEEP will also hold the public hearing

described below. The Commissioner requests that any person giving oral comment

at the hearing also submit a written copy of such comments.

PUBLIC HEARING

9 November 2011 at 11 AM

Department of Environmental Protection, 5th Floor, Holcombe Room

79 Elm Street, Hartford, CT

Copies of the proposal are available for public inspection during normal business

hours and may be obtained from Sharon Rowe-Johnson at the Bureau of Air Management, Engineering & Enforcement Division, 5th Floor, 79 Elm Street, Hartford,

Connecticut. The same documents are posted on DEEP’s website at the following

location:

htt’ www.ct, v /cw /vi~w.asp?a=2684&q=331220~av GID=1619

For further information, contact Robin Baena of the Bureau of Air Management at

(860) 424-4152 or by electronic mail to robin.baena@ct, og~.

DEEP is an affirmative action/equal opportunity employer and service provider.

In conformance with the Americans with Disabilities Act, DEEP makes every effort

to provide equally effective services for persons with disabilities. Individuals with

disabilities who need this information in an alternative format, to allow them to

benefit and/or participate in the agency’s programs and services, should call 860-

424-3035 or e-mail the ADA Coordinator, at DEP.anoffice@ct. og~_. Persons who

are hearing impaired should ca!I the State of Connecticut relay number 711. Requests

for accommodations must be made at least two weeks prior to the program date.

The authority to adopt this proposal is granted by sections 22a-6 and 22a-174 of

the Connecticut General Statutes (CGS). This notice is required pursuant to CGS

sections 22a-6 and 4-168 and 40 Code of Federal Regulations 51.!02.

Daniel C. Esty

Commissioner
Attachment C

Public Hearing Attendees
ATTENDANCE

Public Hearing

November 9, 20l 1

2008 Control Techniques Guidance: Parts Coating and Pleasure Craft Coating

Amendment of RCSA Section 22a-i74-20(s); Adoption of RCSA Section 22a-! 74-20(kk)

Name Organization represented Contact information

(include electronic address)

e l~v~+~" @_. ~e i eo~ ~,<tt,

/A~,~.o ~ ~-~)..~ ~;
Attachment D

Certification of Public Hearing
HEARING CERTIFICATION

This certifies in accordance with the provisions of Title 40 Code of Federal Regulations Part

51.102 that the following actions were taken regarding the proposed amendment or adoption of

various sections of the air quality regulations:

t) The public hearing was held on November 9, 2011 as announced in the notice of

hearing (copy attached);

2) In accordance with the notice, materials were available for review at the

Department of Energy and Environmental Protection and posted on the

Department’s website;

3) Copies of the notice were mailed electronically to the directors of the air pollution

control agencies in New York, New Jersey, Rhode Island and Massachusetts

along with a copy to the Director of the Air Management Division of Region I of

the U.S. Envirormaental Protection Agency; and

4) The notice of hearing was published in the Connecticut Law Journal on

September 27, 201 t and on the Department of Energy and Environmental

Protection’s website.

Date Robin D. Baena

Bureau of Air Management
Attachment E

Hearing Report
Connecticut Department of

ENERGY &

ENVIRONMENTAL

PROTECTION

EXHIBIT E

HEARING REPORT

Prepared Pursuant to Section 4-168(d) of the

Connecticut General Statutes and

Section 22a-3a-3(d)(5) of the Department of Energy and Environmental Protection

Rules of Practice

Regarding

Amendment of Air Quality Regulations Concerning

Parts Coating and Pleasure Craft Coating

Hearing Officer:

Robin D. Baena

Date of Hearing: November 9, 2011

On September 27, 2011, the Corm~aissioner of the Department of Energy and Environmental

Protection (DEEP) published a notice of intent to amend section 22a-174-20(s) of the

Regulations of Connecticut State Agencies (RCSA) and adopt RCSA section 22a-174-20(lck).

Pursuant to such notice, a public hearing was held on November 9, 2011, with the public

comment period closing on the same day.

Hearing Report Content

As required by section 4-168(d) of the Cormecticut General Statutes (CGS), this report describes

the proposal, identifies principal reasons in support of and in opposition to the proposal, and

summarizes and responds to all comments on the proposal.

The proposal is included as Attachment 2 to this report. A final revised version of the proposal

based on the recommendations in this report is included as Attachment 3. A statement in

satisfaction of CGS section 22a-6(h) is included as Attachment 1.

79 Elm Street, Hartford, CT 06106-5127

www.ct,gov/deep

Affirmative Action/Equal Opportunity Employer
I1. Summary of Proposal

The proposal includes the revision of RCSA section 22a-174-20(s) to further limit volatile

organic compounds (VOC) emissions from the coating of metal and plastic parts and the

adoption of RCSA section 22a-174-20(kk) to limit VOC emissions from the coating of pleasure

craft.

The proposal was prepared in response to the U.S. Envirormaental Protection Agency’s (EPA’s)

September 2008 publication of a control techniques guideline (CTO) for miscellaneous metal

and plastic parts coating operations.1 Since Connecticut has been designated as nonattaimment for

ozone, the Clean Air Act requires the state to revise its State Implementation Plan (SIP) to

include reaso~aably available control technology (RACT) for each category of VOC sources for

which EPA has published a CTG. DEEP is proposing revisions to RCSA section 22a-174-20 to

adopt a RACT level of control as established in the 2008 CTG for the miscellaneous metal and

plastic parts coating category. The 2008 CTG updates a 1978 CTO addressing emissions from

miscellaneous metal parts coating,2 which DEEP first adopted as RCSA section 22a-174-20(s) in

1980 and revised in 1993 to increase compliance flexibility: DEEP is proposing to revise

subsection (s) to include plastic parts coating and update the metal parts coating requirements.

EPA includes pleasure craft coating operations within the metal and plastic parts coatings

category in the 2008 CTO. Recognizing the differences in parts coating operations and pleasure

craft coating, DEEP is proposing to address pleasure craft cgating with new subsection (kk) of

RCSA section 22a-174-20, distinct from the requirements applying to metal and plastic parts

coating.

III. Opposition to the Proposal

No submitted comments oppose this proposal.

IV. Summary of Comments

No oral comments were submitted at the hearing, Written comments were received from the

following persons:

Anne Arnold, Manager

Air Quality Planning Unit

USEPA Region 1

5 Post Office Square, Suite 100

Boston, MA 02 t 09-3912

Tom Scelfo, Senior Vice President

Woodard & Curran Inc.

1520 Highland Avenue

Cheshire, CT 06410

2

EPA. Control Tectmiques Guideline for Miscellaneous Metal and Plastic Parts Coatings. EPA-453/R-08-

0373. October 7, 2008.

EPA. Control of Volatile Organic Emissions from Existing Stationary Sources Volume VI Surface Coating

of Miscellaneous Metal Parts and Products. EPA 450/2-78-015- Jtme lg78.

2
Corinne I-Ie~rman

Core EHS, Air Compliance

Sikorsky Aircraft Corp.

6900 Main Street, M/S 201A

Stratford, CT 06675-9129

Eugene Brackbill,

SCI-TECH, Inc.

ebrackbitl@sci-techinc.com

All comments submitted are summarized below with DEEP’s responses. Commenters are

associated with the individual comments below by the number assigned above. When changes to

the proposed text are indicated in response to comment, new text is in bold font and deleted text

is in strikethrough font.

Subsection _(s) - Miscellaneous Metal and Plastic Parts

Comment 1: Given that the date for compliance with the relevant emissions limits is stated as

January 1, 2013 in subsection (s)(3), it is not clear why subsection (s)(10)(B) states that requests

for permit revisions to limit a facility’s potential to emit are also due January 1, 2013. (1)

Response: DEEP agrees that the submittal date and compliance date cannot coincide,

since it would take time for a request for a permit or order revision to be approved.

Further, the proposal does not allow the owner of a facility to submit a request for a

revision after the compliance date, nor does it allow the owner of a facility that is not

currently operating under an order or permit to apply for such a limitation. DEEP

appreciates EPA’s comment to allow for the proposal to be revised to align with DEEP’s

intent on these points. An owner of a facility may request a new order or a revision at any

time. If an owner submits a request without allowing for sufficient approval time, the

owner must operate in compliance with subsection (s) in the interim between the

compliance date and approval of their request, if provided. Including an enforceable

deadline in subsection (s)(10) is not necessary. Information concerning requesting or

revising a permit or order will be included ila the Regulatory Assessment Document

DEEP prepared as teclmical support for this proposal and will be communicated to

stakeholders as part of DEEP’s outreach efforts concerning the new requirements.

To be consistent with DEEP’s intern, subsection (s)(10) should be revised as follows:

3
(10) Limitations on potential to emit.

An owner or operator may submit a request to the commissioner for

an order or permit to limit potential emissions from all miscellaneous

metal and plastic parts coating at the premises to a monthly limit of

1,666 pounds of VOC; or

An owner or operator issued a permit or order prior to January 1,

2013 pursuant to former section 22a-174-20(s)(7) of the Regulations of

Connecticut State Agencies may:

(i) Continue after January 1, 2013 to conduct miscellaneous metal

parts coating in compliance with such a permit or order,

(ii) Submit a request to the commissioner to modify the order or

permit to include all miscellaneous metal and plastic parts

coating at the premises in the monthly limit of 1,666 pounds of

VOC, or

(iii) Submit a request to the commissioner to revoke the order or

permit.

Comment 2: Several locations in the proposal allow the commissioner to make case-by-case

approvals for coating exemptions and alternative test methods. Provisions with such state

discretion are not acceptable for approval into the SIP. Therefore, DEEP should revise the

following subsections to also require EPA approval where it cites commissioner approval:

(s)(Y)(J), (s)(8)(B)(vi), (s)(9)(C), (kk)(7)(B)(vi), and (kk)(8)(C). (1)

Response: As suggested in the comment, DEEP should require EPA administrator and

DEEP commissioner approval of case-by-case coating exemptions and alternative test

methods in subsections (s)(7)(J), (s)(8)(B)(vi), (s)(9)(C), (kk)(7)(B)(vi), and (kk)(8)(C).

As a result, subsection (s)(7)(J) should be revised as follows:

The requirements of subdivision (3) of this subsection shall not apply, upon

request to and approval by the commissioner and the Administrator...

The text of subsection (s)(8)(B)(vi) should be moved to subsection (s)(8)(A)(vi), as

explained in the response to Comment 15, and revised to read as follows:
Documentation of control device efficiency and capture efficiency, if applicable,

using an applicable EPA reference method or alternate method as approved by the

commissioner and the Administrator, and

Subsection (s)(9)(C) should be revised as follows:

To determine the properties of a coating or components thereof in order to

perform the calculations required pursuant to subparagraph (A) of this subdivision

or to verify calculations based on the manufacturer’s formulation data, the VOC

and solids content of all coatings shall be determined using 40 CFR 60, Appendix

A, Reference Method 24 or an equivalent method. In the case of a dispute, the

VOC content detm~-nined using Reference Method 24 shall control, unless a

person is able to demonstrate to the " " ’ ~ " satisfaction of

the commissioner and the Administrator that the manufacturer’s formulation

data are correct.

The text of subsection (kk)(7)(B)(vi) should be moved to subsection (kk)(7)(A)(vi),

as explained in the response to Comment 15, and be revised to read as follows:

Documentation of control device efficiency and capture e£ficiancy, if applicable,

using an applicable EPA reference method or alternate method as approved by the

commissioner and the Administrator, and

Subsection (kk)(8)(C) should be revised as follows:

To detennine the properties of a coating or components thereof in order to

perform the calculations required pursuant to subparagraph (A) of this subdivision

or to verify calculations based on the m~nufacturer’s formulation data, the VOC

and solids content of all coatings shall be determined using 40 CFR 60, Appendix

A, Reference Metl~od 24 or an equivalent method. In the case of a dispute, the

VOC content determined using Reference Method 24 shall control, unless a

person is able to demonstrate to the ccmmis~ione~ satisfaction of

the commissioner and the Administrator that the manufacturer’s formulation

data are correct.

Comment 3: DEEP’s proposed emission limit for miscellaneous metal and plastic parts product

coating operations are consistent with EPA’s 2008 CTG for Miscellaneous Metal and Plastic

Parts Coating (MMPPC). However, the proposed limits for certain specialty coatings are less

stringent than Connecticut’s existing SIP-approved rule. Therefore, when DEEP submits the

revised rule to EPA as a SIP revision, the state must also address the anti-backsliding provisions

of Sections 110(I) of the Clean Air Act. (1)

Response: Although a few proposed coating limits in the subsection (s) of RCSA section

22a-174-20 are less stringent than the current limits, most of the proposed limits are more

stringent and more coating categories are regulated. The combination of new coating

categories, more stringent limits and broader applicability means that RCSA section 22a174-20, amended as recommended in this report, will be more protective of air quality

5
than the current RCSA section 22a-174-20. DEEP will address EPA’s concerns in more

detail in the SIP revision following completion of the rule making process.

Comment 4: Revise the "EMI!RFI shield coating" definition in subsection (s)(1)(WW) by

adding "or static discharge" to be consistent with CTG recommended definition. (4)

Response: In the final text of RCSA section 22a-174-20(s)(l)(WW), DEEP should

revise the definition of~°EMI/RFI shield coating" to read as follows:

"EMI/RFI shield coating" means a coating that functions to attenuate

electromagnetic interference, ~ radio frequency interference signals or static

discharge;

Comment 5: Revise the ’~pretreatment coating" definition in subsection (s)(1)(FFFF) by adding

"and to provide corrosion resistance" to be consistent with CTG recommended definition. As

currently drafted, a limit for this coating type appears only in Table 20(s)-6a: Aerospace

Specialty Coating Limits. DEEP should consider including the coating type in Table 20(s)-l:

Metal Parts Coating VOC Limits. These coatings can also be used for non-aerospace

equipment. As currently drafted, non-aerospace facilities using pretreatment coatings would be

subject to the general coating category limits, which are substantially lower and would seem

inappropriate. (4)

Response: DEEP should revise the definition of"pretreatment coating" in the final text

of RCSA section 22a-174-20(s) to be consistent with the 1997 aerospace CTG as follows:

"Pretreatment coating" means a coating, containing at least 0.5 percent acid by

weight, applied directly to a metal or composite surface to provide surii~ce

etching, corrosion resistance, adhesion and ease of stripping;

The 1997 aerospace CTG identifies "pretreatment coating" as a specialty coating for the

aerospace industry, while the 2008 MMPPC CTG does not. We must, therefore,

conclude that EPA intended this type of coating to be categorized as a general coating,

subject to the general category limit when used outside of aerospace applications. States

may implement controls other than those recommended in a CTG to impose a level of

control at least as stringent as that recommended in a CTG. Since adopting the aerospace

pretreatment coating limits for coating in non-aerospace applications would constitute

less stringent controls, DEEP should not revise the proposal in response to this corrmaent.

Comment 6: Revise the ’~Sealant" definition in subsection (s)(1)(TTTT) by adding "There are

two categories of sealants: extrudable/rollable/bmshable sealants and sprayable sealants" to be

consistent with the definition in Control of Volatile Organic Compound Emissions from Coating

Operations at Aerospace Manufacturing and Rework Operations (EPA-453/R-97-004, December

1997). (4)

Response: DEEP should make no change to the proposal in response to this comment.

The two categories of sealants are listed in Table 20(s)-6a and do not need to be repeated

6
in the definition to clarify applicability. The cun’ent definition is sufficient to describe

"sealant" coatings.

Comment 7: In Table 6b of the draft regulation, it appears that the primer and topcoat coating

categories from the Aerospace NESHAP were incorporated, but definitions were left out of the

draft rule. Definitions m~d clarification on what coating limits apply are needed.

The Aerospace NESHAP has the following definitions:

General aviation rework facility means any aerospace facility with the majority of its

revenues resulting from the reconstruction, repair, maintenance, repainting, conversion,

or alteration of general aviation aerospace vehicles or components.

Large commercial aircraft, means an aircraft of more than 110,000 pounds, maximum

certified take-off weight manufactured for non-military use. (3)

Response: The coating limits in Table 20(s)-6b are the same as those in the aerospace

NESHAP and are intended to apply to the same sources. To make this intent clear, DEEP

should add the following definitions to subdivision (1) of subsection (s) in the appropriate

alphabetica! location. The other definitions in the subdivision should be re-lettered, as

necessary:

"General aviation rework facility" means any aerospace facility with the

majority of its revenues resulting from the reconstruction, repair,

maintenance, repainting, conversion or alteration of general aviation

aerospace vehicles or components;

"Large commercial aircraft" means an aircraft of more than 110,000 pounds,

maximum certified take-offweight, manufactured for non-military use;

Comment 8: Regardless of whether or not a limit has been established for a specific material,

the material should be defined. Several materials identified in the draft regulation are not

defined:

Fog coat

Gloss reducer

High performance architectural coating

Mask coating

Motor vehicle bedliner coating

Motor vehicle gasket/gasket sealing material

Motor vehicle lubricating/wax compound

Motor vehicle sealer

Motor vehicle trunk interior coating

Motor vehicle underbody coating

Multi-colored coating

Two component coating (4)
Response: To al!ow for all due clarity, DEEP should add the following definitions, located

alphabetically, to the final text of RCSA section 22a-174-20(s)(1). Definitions in the

subdivision should be re-ordered and re-lettered, as necessary, to accommodate the new

definitions:

"Fog coat" means a coating that is applied to a plastic part at a thickness of no

more than 0.5 mils of coating solids for the purpose of color matching without

masking a molded-in texture;

"Gloss reducer" means a coating that is applied to a plastic part at a thickness of

no more than 0.5 mils of coating solids solely to reduce the shine of the part;

"High-performance architectural coating" means a coating used to protect

architectural subsections and that meets the requirements of the Architectural

Aluminum Manufacturer Association’s publication number AAMA 2604-05

(Voluntary Specification, Performance Requirements and Test Procedures for

High Performance Organic Coatings on Aluminum Extrusions and Panels) or

2605-05 (Voluntary Specification, Performance Requirements and Test

Procedures for Superior Performing Organic Coatings on Aluminum Extrusions

and Panels);

"Mask coating" means thin film coating applied through a template to coat a

small portion of a substrate;

"Motor vehicle bedliner coating" means a multi-component coating applied to a

cargo bed after the application of a topcoat to provide additional durability and

chip resistance;

"Motor vehicle cavity wax" means a coating applied into the cavities of the

vehicle primarily for the purpose of enhancing corrosion protection;

"Motor vehicle deadener" means a coating applied to selected vehicle surfaces

primarily for the purpose of reducing the sound of road noise in the passenger

compartment;

"Motor vehicle gasket/sealing material" means a fluid applied to coat a gasket or

replace and perform the same function as a gasket. Automobile and light-duty

truck gasket/gasket sealing material includes room temperature vulcanization

seal material;

"Motor vehicle lubricating wax/compound" means a protective lubricating

material applied to vehicle hubs and hinges;

"Motor vehicle sealer" means a high viscosity material generally, but not always,

applied in the paint shop after the body has received an electrodeposition primer

coating and before the application of a subsequent coating (e.g., primersurfacer). The primary purpose of automobile and light-duty truck sealer is to

8
fill body joints completely so that there is no intrusion of water, gases or

corrosive materials into the passenger area of the body compartment;

"Motor vehicle trunk interior coating" means a coating applied to the trunk

interior to provide chip protection;

"Motor vehicle underbody coating" means a coating applied to the

undercarriage or firewall to prevent corrosion or provide chip protection;

"Mnlti-colored coating" means a coating packaged in a single container and

applied in a single coat which exhibits more than one color when applied;

Subsection (s)(1)(U) of the proposal contains a definition of "cavity wax" and subsection

(s)(1)(KK) contains a definition of"deadener." These terms are specific to motor vehicle

coating applications and the above "motor vehicle" definitions are more specific. To avoid

redundancy, in the final text the "cavity wax" and "deadener" definitions should be deleted

from subsection (s)(1):

~De-ade~r" ’ " " ~ ~~4acAe4we~

The term "two-component coating" is not used in the proposal, so a definition is not

necessary. Two-component coatings are classified as multi-component coatings. RCSA

section 22a-174-20(s) includes a definition and limits for multi-component coatings.

Comment 9: VOC content limits are established for vacuum-metalizing coatings applied to

metal parts and plastic parts. The definition at subsection (s)(!)(OOOOO) is consistent with the

CTG recommended definition for metal parts coating:

"Vacuum-metalizing coating" means an undercoat applied to a substrate on which metal

is deposited or an overcoat applied directly to a metal film;

The CTG recommended definition for plastic part vacuum metalizing coating is sufficiently

different so that it should be included:

"Vacuum-metalizing coating" as applied to metal parts means the undercoat

applied to the substrate on which the metal is deposited or the overcoat applied

directly to the metal film. With resRg~_t to plastic parts, vacuum-metalizing

coatin~ means topcoats and basecoats that are used in the vacuum-metalizing

process." (4)

Response: The definition of"vacuum-metalizing coating" does not differ for the

different substrates in any meaningful way. A topcoat and overcoat are substantially the
same, as are basecoats and undercoats, in this application. However, clarification of the

definition is required. In the final text of subsection (s)(t), the definition of"vacuummetalizing coating" should be revised as tbllows:

"Vacuum-metalizing coating" means the undercoat applied to ~he a

substrate on which the metal is deposited prior to a vacnum-metalizing

process or the overcoat applied directly to the metal film alter a vaeuummetalizing process;

A corresponding definition of"vacumn-metalizing process" should also be added

to subsection (s)(1), as follows:

"Vacuum metalizing process" means the process of evaporating

metals inside a vacuum chamber and depositing them on a substrate

to achieve a uniform metalized layer;

Comment 10: The definition of wing coating should include rotary wings. (3, 4)

Response: In the fin!l text of subsection (s)(1), the definition for "wing coating" should

be revised as follows:

"Wing coating" means a corrosion-resistant topcoat that withstands the flexing of

aircraft wings and rotary wings.

Comment 11: In subsection (s)(2)(A)(ii), it is not clear why the applicability criteria only applies

to "the owner" and not to both "the owner and operator," as stated throughout the remainder of

the rule. (1)

Response: This omission is an oversight. Subsection (s)(2)(A)(ii) should be revised to

read as follows:

For which the owner or operator purchases for use at the premises 855 gallons or

more of coatings and cleaning solvents in aggregate per rolling 12-month period.

Comment 12: We believe that the intent of the CTG is for the regulation to apply to products

that are manufactured by the facility for sale or use at another location. To avoid different

interpretations, please clarify that RCSA section 22a-174-20(s) is intended to apply only to

production parts and not to other components at the facility that are not "products," such as jigs

and fixtures or equipment used to manufacture the products, or metal or plastic items at the

facility that are not products manufactured by the facility for sate or use at another location. (2)

Response: The MMPPC CTG indicates that EPA intends the recommended controls to

apply to "manufacturers of miscellaneous metal and plastic parts that surface coat the

parts they produce" and "facilities that perform surface coating of miscellaneous metal

and plastic parts on a contract basis." DEEP does not intend for the maintenance coating

of facility fixtures, equipment and components to be regulated under subsection (s). To

clarify, the following exemption should be added to subdivision (7)(A) as clause (xiii):

10
(7) Exemptions and exceptions.

Except as provided in subdivision (8) of this subsection, the requirements

of this subsection shall not apply to any of the following activities, and the

VOC emissions resulting from the following activities shall not be

included in detel~inations pursuant to subdivision (2) or (7)(G) of this

subsection: ...

(xiii) Maintenance coating and related cleaning of fixtures,

equipment and components that are not products

manufactured by the facility or products coated’on a contract

basis.

Comment 13: Subsection (s)(4)(I) states "Any owner or operator using an application method

pursuant to this subparagraph shall maintain records demonstrating the transfer efficiency

achieve&" Is my interpretation con’ect that the requirement applies only to (4)(I) and not to all

of subdivision (4)? If not, "subparagraph" should be clearly described as applying only to (4)(I)

and not the entire paragraph (4). Perhaps my understanding of "paragraph" and "subparagraph"

as used in the regulation is confused. (4)

Response: According to the State of Cormecticut Manual for Draftin~ R~_~gulations

prepared by the Legislative Commissioner’s Office (Rev Dec. 2009, page 24), regulations

are divided as follows:

Section (e.g. 22a-! 74-20)

Subsection (e.g. (s))

Subdivision (e.g. (4))

Subparagraph (e.g. (I))

Clause (e.g. (i))

Subclause (e.g. (IV))

Therefore, the requirement to maintain records demonstrating the transfer efficiency

achieved would not apply to all of subdivision (4), but only to subparagraph (I) of

subdivision (4). Since this interpretation is based on well established and published

policy, no further clarification is necessary.

Comment 14: To be eligible for the shipbuilding and ship repair exemption of proposed section

22a-174-20(s)(7)(A)(v), the owner of a facility that applies coatings must ~operate in compliance

with 40 CFR 63 Subpart II." We agree with the premise that a facility must be more than just

"subject to" 40 CFR 63 Subpart II in order to be exempt from 22a-174-20(s), but are concerned

that "operate in compliance" could be subject to interpretation by different inspectors. As a

suggestion, perhaps "operate in compliance" could be replaced with "operate in substantial

compliance" or similar wording. Otherwise, please provide some clarification as to the term

°~operate in compliance." (2)

11
Response: DEEP does not intend for facilities that have failed in their obligation to

comply with 40 CFR 63 Subpart II to also be in noncompliance with RCSA section 22a174-20(s). For instance, a recordkeeping violation under Subpart II should not eliminate

a source from using the exemption provided in proposed subsection (s)(7)(A)(v). To

prevent disagreements about how much compliance is enough, the compliance phrase

should be deleted from the proposed language. The obligation to comply with the federal

requirements exists independently. Subsection (s)(7)(A)(v) should, therefore, be revised

as follows:

Coating applied in a shipbuilding and repair operation, provided that the operation

is subject to ~rating in comp!iance with 40 CFR 63 Subpart II,

Comment 15: Per proposed RCSA section 22a-174-20(s)(7)(A)(v), shipbuilding and ship repair

thcilities.., are exempt from 22a-174-20(s), except for record keeping requirements under

section 22a-174-20(s)(8). Section 22a-174-20(s)(8)(D) states that the facility must retain

"records sufficient to verify the applicability of the exception or exemption." We interpret that

requirement to mean records that demonstrate that the facility is ~°operating in compliance with

40 CFR 63 Subpart II" as required by section 22a-174-20(s)(7)(A)(v), such as an initial

notification, implementation plan, and semi-annual reports. In accordance with section 22a-174-

20(s)(8)(A), those records would need to be maintained for five years and made available upon

request.

Please clarify whether the additional record keeping requirements under 22a-174-20(s)(8)(B) are

also required. (2)

Response: DEEP’s intention is that a coating operation granted an exception or

exemption would only need to keep "records sufficient to verify the applicability of the

exception or exemption," maintain those records for five years, and make them available

upon request Any coating operation that is exempt or does not meet the applicability

thresholds would not be subject to subparagraph (B) of subsection (s)(8) of the proposal.

To clarify, subsection (s)(8) should be revised as follows:

(8) Records.

Except as provided in subparagraphs (B) and (C), A~ an owner or

operator shall maintain records of information sufficient to deterraine

compliance with the applicable requirements of this subsection, including, at a

minimum, the following infomlafiun deser4bed in subpamgrap~

subdivision. A!~-such r~cords~MPbe for each calendar month:

(i)-Made-a~ai!aS!e to the comm~issioner to inspeet-and copy upon

om the dae ~rd

2m ownar or operator sM! " " -" 51!owing inf~

each ca!end~ m~

12
(i) Name and description of each coating and cleaning solvent,

(ii) VOC content of each coating and cleaning solvent, as applied, and the

associated calculations,

(iii) VOC content of each coating or cleaning solvent, as supplied,

(iv) The amount of each coating and cleaning solvent:

(I) Purchased, or

(II) A~al4y-~ed Used,

(v) A Material Safety Data Sheet, Environmental Data Sheet, Certified

Product Data Sheet, or an equivalent data sheet for each coating and

cleaning solvent,

(vi) Documentation of control device efficiency and capture efficiency, if

applicable, using an applicable EPA reference method or alternate

method as approved by the commissioner and the Administrator, and

(vii) Date and type of maintenance perfo~med on air pollution control

equipment, if applicable.

Any owner or operator who does not meet the applicability thresholds

provided in subdivision (2)(A) of this subsection shall maintain either material

purchase or actual usage records to verify that this subsection does not apply

to such owner or operator.

An owner or operator operating pursuant to an exception or exemption in

subdivision (7) of this subsection shall maintain records sufficient to verify

the applicability of the exception or exemption.

All records made pursuant to this subdivision shal~ be:

(i) Made available to the commissioner to inspect and copy upon

request, and

(ii) Maintained for five years from the date such record is created.

(D)

In addition, to improve clarity and maintain consistency between subsections (s) and (kk),

proposed subsection (kk)(7) should be revised as follows:

(7) Records.

13
(A) Except as provided in subparagraphs (B) and (C), ~ an owner or

operator shall maintain records of information sufficient to determine

compliance with the applicable requirements of this subsection, including, at a

minimum, the following information ~rapk (B)w^~÷~;~...~o

 ̄

" " . ’ ~ for each calendar month:

following info.’v~

(i) Name and description of each coating and cleaning solvent,

(ii) VOC content of each coating and cleaning solvent, as applied, and

the associated calculations,

(iii) VOC content of each coating or cleaning solvent, as supplied,

(iv) The amount of each coating and cleaning solvent:

(I) Purchased, or

(II) ~d Used,

(v) A Material Safety Data Sheet, Envirormaental Data Sheet, Certified

Product Data Sheet, or an equivalent data sheet for each coating

and cleaning solvent,

(vi) Documentation of control device efficiency and capture efficiency,

if applicable, using an applicable EPA reference method or

alternate method as approved by the commissioner and the

Administrator, and

(vii) Date and type of maintenance performed on air pollution control

equipment, if applicable.

( -)(B) Any owner or operator who does not meet the applicability thresholds

provided in subdivision (2)(A) of this subsection shall maintain either material

purchase or actual usage records to verit~¢ that this subsection does not apply

to such owner or operator.

(:D)(C) An owner or operator operating pursuant to an exception or exemption in

subdivision (3) of this subsection shall maintain records sufficient to

verify the applicability of the exception or exemption.

14
(D) All records made pursuant to this subdivision shall be:

(i) Made available to the commissioner to inspect and copy upon

request, and

(ii) Maintained for five years from the date such record is created.

Comment 16: Proposed RCSA section 22a-174-20(s)(8)(B)(ii) states that records must be

maintained of the °’VOC content of each coating and cleaning solvent, as applied, and the

associated calculations." We suggest replacing the words "cleaning solvent" with "diluent."

Otherwise, there would be no need for any "associated calculations." In addition, RCSA section

22a-174-20(s)(8)(B)(iii) already includes record keeping requirements for the VOC content of

the cleaning solvent. (2)

Response: In the final text of this proposal, section 20(s)(8)(B)(ii) of the proposal should

be moved to subsection 20(s)(8)(A)(ii), as explained in the response to Comment 15, and

be revised as follows:

VOC content of each coating and ~ve~ diluent, as applied, and the

associated calculations,

For the same reasons as stated in this comment, "diluent" should replace "cleaning

solvent" in proposed RCSA section 22a-174-20(kk)(7)(B)(ii). This text should be moved

to subsection (kk)(7)(A)(ii), as explained in the response to Corm~nent 15, and be revised

as follows:

VOC content of each coating and cdea~in~ diluent, as applied, and the

associated calculations,

As suggested in this comment, cleaning solvents and diluents are distinct materials.

Subsections (s)(5) and (kk)(6) specify work practice requirements for VOC-containing

coatings and cleaning solvents, but not diluents. Since diluents also need to be handled in

a manner that limits VOC emissions, diluents should be included in the work practice

requirements of both subsections. Therefore, subsections (s)(5) and (kk)(6) should be

revised to read as follows:

Work practices. Each owner or operator shall use the following work practices:

(A) New and used VOC-containing coating, diluent or cleaning solvent,

including a coating mixed on the premises, shall be stored in a

nonabsorbent, nondeaking container. Such a container shall be kept

closed at all times except when the container is being filled, emptied or is

otherwise actively in use;

I5
(B)

(c)

(D)

Spills and leaks of VOC-containing coating, diluent or cleaning solvent

shall be minimized. Any leaked or spilled VOC-containing coating,

diluent or cleaning solvent shall be absorbed and removed immediately;

Absorbent applicators, such as cloth and paper, which are moistened with

a VOC-containing coating or solvent, shall be stored in a closed,

nonabsorbent, non-leaking container for disposal or recycling; and

VOC-containing coating, diluent and cleaning solvent shall be conveyed

from one location to another in a closed container or pipe.

Subsection (kk) - Pleasure Craft Coating

Comment 17: In Table 20(kk)-l, "Pleasure Craft Coating VOC Limits," Cormecticut’s

proposed limits for Extreme High Gloss Topcoat and Other Substrate Antifoulant Coating are

less stringent than EPA’s 2008 CTG tbr MMPPC operations. In addition, Connecticut is

proposing an Antifouling Sealer/Tie Coating category with a less stringent limit than the CTG

Other Substrate Antifoutant category. The technical analysis contained in Connecticut’s

Regulatory Assessment Document addresses this issue and should be included in Connecticut’s

SIP submittal for this regulation. (1)

Response: DEEP appreciates EPA’s suggestion and will include the technical analysis

contained in Connecticut’s Regulatory Assessment Document in Connecticut’s SIP

submittal for this regulation. DEEP should not revise the proposal in response to this

comment.

V. Comments of Hearing Officer

The hearing officer suggests the following additional revisions to the proposal. The suggested

revisions are minor, noncontroversial and will make for a clearer final proposal.

(1) The definition of"air dried" located at subsection (s)(1)(F) of the final text of the

proposal should be revised to replace the word degrees with it symbol for consistency with the

other defined terms in the section, as follows:

"Air dried" means cured at a temperature below 90 °C (194 degrees °F);

(2) The definition of"automotive-transportation parts" located at subsection (s)(1)(M) of the

final text of the proposal should be revised from plural to singular for consistency with the other

defined terms in the section, as follows:

"Automotive-transportation pa~ part" means ~e an interior and or exterior components

component of a motor ,¢eNcAes-and vehicle or mobile so~-ees source;

16
(3) The definition of"caulking and smoothing compounds" located at subsection (s)(1)(T) of

the final text of the proposal should be revised from plural to singulm" for consistency with the

other defined terms in the section as follows:

"Caulking and smoothing ~ compound" means a semi-solid mat~4als

material that a-re is applied by hand and am used to smooth exterior vehicle surfaces or

fill cavities such as bolt hole accesses. A material shal! not be classified as a "caulking

and smoothing compound" if it can also be classified as a sealant;

(4) The second sentence of the "commercial interior adhesive" definition located at

subsection (s)(!)(BB) of the final text of the proposal applies to the components being coated

and not the adhesive. The definition should, therefore, be revised as fol!ows:

"Comroercial interior adhesive" means a ma4e+iats material used in the bonding of

passenger cabin interior components. T-~ae÷c componer~ ~a44ma

Administration fire;~i~ae-ss requirements;

(5) The definition of"corrosion prevention compound" located at subsection (s)(1)(EE) of

the final text of the proposal should be revised as follows:

"Corrosion prevention compound" means a coating system tha:~ provides corrosion

protection by displacing water and penetrating substrates, forming a protective barrier

bet~veen the metal surface and moisture, goa44~gs A coating containing oils or waxes ar~

is excluded from this category;

(6) The first word of each clause of the definition of "related cleaning" located at subsection

(s)(1)(WWWW) of the final text of the proposal should be capitalized as follows:

"Related cleaning" means the removal of uncured coatings, coating residue and

contaminants from:

(i)

(ii)

(iii)

mi:sc4A:a~ae~as Miscellaneous metal and plastic parts prior to the

application of coatings,

mise+tl, a~ Miscellaneous metal and plastic parts between coating

applications, or

~ Trm~sfer lines, storage tanks, spray booths and coating

application equipment;

(7) Subdivision (3) of subsection (s) of the final text of the proposal shouId be revised to

make the punctuation consistent with other subdivisions by replacing the period at the end of

subparagraphs (A) tl~’ough (C) with a semicolon as follows:

Except as provided in subdivision (7) of this subsection, on and after January 1, 2013, no

owner or operator shall apply any coating, inclusive of any VOC-containing materia!

added to the original coating supplied by the manul~actnrer, unless the owner or operator

17
controls emissions of VOCs in accordance with subparagraph (A), (B), (C) or (D) of this

subdivision. If more than one emission limit or emission rate applies in a particular

situation, then the least restrictive limit or emission rate shall apply. An owner or

operator shall control the emission of VOCs as follows:

Use only coatings that have an as applied VOC content no greater than the

applicable level in Table 20(s)-l, 20(s)-2, 20(s)-3, 20(s)-4, 20(s)-5, 20(s)-

6a or 20(s)-6b,;

For a coating unit, use a combination oflow-VOC coatings and add-on air

pollution control equipment to achieve a VOC emission rate no greater

than the applicable level in Table 20(s)-7, 20(s)-8, 20(s)-9, or 20(s)-10~;

Install, operate and maintain according to the manufacturer’s

recommendations air pollution control equipment with an overall control

efficiency of at least 90%,; and

An alternative means, achieving a level of control equivalent to

subparagraph (A), (B) or (C) of this subdivision, requested from and

approved by the commissioner in accordance with subsection (cc) of this

section.

(8) The definition of"related cleaning" located at subsection (kk)(1)(T) of the final text of

the proposal should be revised to make the punctuation consistent with other definitions by

replacing the semicolon at the end of clauses (i) and (ii) with a colon and capitalizing the first

word of each clause as follows:

"Related cleaning" means the removal of uncured coatings, coating residue, and

contaminants from:

(i) p~ Pleasure craft or parts and components of pteasure craft prior to

the application of coatingsl,

(ii) ~ Pleasure craft or parts and components of pleasure craft between

coating applications~, or

(iii) ~ Transfer lines, storage tanks, spray booths, and coating

application equipment; and

(9) Subdivision (2) of subsection (kk) of the final text of the proposal should be revised to

make the punctuation consistent with other subdivisions by replacing the period at the end of

subparagraphs (A) and (B) with a semicolon as follows:

Applicability.

(A) Except as provided in subdivision (3) of this subsection, the provisions of this

subsection apply to the owner or operator of any marina, boat yard, or other

18
premises where pleasure craft coating is applied for commercial purposes at the

direction of such owner or operator, if:

Such owner or operator was subject to subsection (s) of this section prior

to January 1, 2013, or

(ii) Such owner or operator purchases for use in all pleasme craft coating and

related cleaning at the premises 855 gallons or mor4 of coatings and

cleaning solvents in aggregate per rolling 12-month perio&;

(B) An owner or operator subject to this subsection shall:

(c)

(i) For a source operating prior to January 1, 2013, comply with the

requiremeuts of this subsection no later than Jannary 1, 2013, or

(ii) For a source that conm~ences operation after January 1, 20!3, comply with

the requirements of this subsection upon commencing operation.; and

Any owner or operator subject to this subsection shall remain subiect to this

subsection.

(10) Subdivision (4) of subsection (lck) of the final text of the proposal should be revised to

make the punctuation consistent with other subdivisions by replacing the period at the end of

subparagraphs (A) through (D) with a semicolon as follows:

On and after January 1, 20 t3, no owner or operator of a pleasure craft coating operation

shall apply any coating, inclusive of any VOC-containing material added to the original

coating supplied by the manufacturer, unless the owner or operator controls emissions of

VOCs in accordance with subparagraph (A), (B), (C), (D) or (E) of this subdivision, tf

more than one emission limit or emission rate applies in a particular situation, then the

least restrictive limit or rate shall apply. An owner or operator shall:

Use only coatings that have m~ as applied VOC content no greater than the

applicable level in Table 20(kk)-l=;

(B) Use a combination of low-VOC coatings and add-on air pollution control

equipment to achieve a VOC emission rate no greater than the applicable level in

Table 20(kk)-2=;

(c)Install, operate and maintain according to the manufacturer’s recommendations

air pollution control equipment with an overall control efficiency of at least 90%~;

Use an alternative means, achieving a level of control equivalent to subparagraph

(A), (B) or (C) of this subdivision, requested from and approved by the

co~rm~issioner in accordance with subsection (cc) of this section.-; and

19
Limit the total potential VOC emissions from all pleasure craft coating operations

and related cleaning by permit or order of the commissioner to 1,666 pounds or

less in any calendar month.

VI. Conclusion

Based upon the comments addressed in this Hearing Report, I recommend the proposal be

revised as recommended herein and that the recommended final proposal, included as

Attachment 3 to this report, shall be submitted by the Commissioner for approval by the

Attorney General and the Legislative Regulations Review Committee and upon adoption, be

submitted to the EPA as a SIP revision.

Robin D. Baena

Hearing Officer

02. ,//o/~ / 2__

Date

20
Attachment 1

STATEMENT PURSUANT TO SECTION 22a-6(h) OF THE GENERAL STATUTES

CONCERNING THE ADOPTION OF ][~EGULAT1ONS PERTAINING TO ACTIVITIES

FOR WHICH THE

FEDERAL GOVERNMENT HAS ADOPTED STANDARDS OR PROCEDURES

Pursuant to section 22a-6(h) of the Connecticut General Statutes (CGS), the Commissioner of the

Department of Energy and Enviromnental Protection (the Department) is authorized to adopt

regulations pertaining to activities for which the federal government has adopted standards or

procedures. At the time of public notice, the Commissioner must distinguish clearly all

provisions of a regulatory proposal that differ from federal standards or procedures either within

the regulatory language or through supplemental documentation accompanying the proposal. In

addition, the Commissioner must provide an explanation for all such provisions in the regulationmaking record required under CGS Title 4, Chapter 54 and make such explanation publicly

available at the time of the publication of the notice of intent required under CGS section 4-168.

In accordance with the requirements of CGS section 22a-6(h), the foliowing statement is entered

into the administrative record in the matter of the proposed revisions to section 22a-174-20(s) of

the air quality regulations.

This proposal revises RCSA subsection 22a-174-20(s) to further limit VOC emissions from the

coating of metal and plastic parts and adopts RCSA 22a-174-20(kk) to limit VOC emissions

from the coating of pleasure craft.

The Department has performed a comparison of the proposal with analogous federal laws and

regulations, namely the Clema Air Act (CAA) and standards and procedures in 40 Code of

Federal Regulations (CFR), as follows:

~ the revision of subsection (s) and adoi~,ion of subsection (kk) in RCSA section 22a174-20: There are no comparable federal standards specifying a reasonably available control

technology (RACT) level of control, although Clean Air Act section 182(b) requires states to

establish a RACT level of control for certain categories of soarces. EPA does issue control

technique guidelines (CTGs) that recommend work practices, application methods, refo~nulation

and/or control equipment operation that EPA considers a RACT level of control for a source

category or activity, but the adoption of enforceable requirements that meet at least that

recommended level of control is left to each state with a nonattainment area for an ozone

national ambient air quality standard. The proposed requirements for miscellaneous metal and

plastic parts coating and pleasure craft coating are consistent with the recommendations of the

miscellaneous metal and plastic parts coating CTG and provide at least a RACT level of control.

Date Robin D. Baena

Attachment 2

Proposal

Section 1. Subsection (s) of section 22a-174-20 of the Regulations of Connecticut State

Agencies is amended to read as follows:

(s) Miscellaneous metal and plastic parts [and products.]

[(1) For the purpose oftbis subsection:

"Air dried coating" means a coating that is dried by the use of air or forced warm air at

temperatures up to below 90 degrees C (I 94 degrees F).

"Clear coat" means a base or top coating which either lacks color and opacity or which is

transparent and uses the surface to which it is applied as a reflectant base or undertone color.

"Coating application system" means all operations and equipment that apply, convey and dry a

surface coating, including, but not limited to, spray booths, flow" coaters, flashoff areas, air dryers

and ovens.

"Exposure to extreme enviro~m~ental conditions" means exposure to: the weather all of the time;

temperatures consistently above 95 degrees C; detergents; abrasive and scouring agents;

solvents; co~a’osive atmospheres; or similar environmental conditions as determined by the

commissioner and the Administrator.

"Extreme performance coatings" means coatings designed for exposure to extreme

environmental conditions.

"Heat sensitive material" means materials that cannot consistently be exposed to temperature

greater than 95 degrees C (203 degrees F) for more than 30 seconds.

"High performance architectural aluminum coating" means a coating that is applied to

architectura! aluminum panels, extrusions or subsections to meet the specifications of publication

number AAMA 605.2-1992 of the Architectural Aluminum Manufacturer’s Association.

"Prime coat" means the first of two or more films of coating applied to a meta! surface.

"Single coat" means one film of coating applied to a metal surface.

"Topcoat" means the final film or series of films of coating applied in a two-coat (or more)

operation.

"Transfer efficiency" means the portion of coating solids that adheres to the metal surface during

the application process, expressed as a percentage of the total volume of coating solids delivered

by the applicator.

(2) Applicability. For the purpose of this subsection:

(A) Miscellaneous metal parts and products includes the following industrial

categories:
DRAFT

2

(i)

(ii)

(iii)

(iv)

(v)

(vi)

(vii)

Large farm machinery such as harvesting, fertilizing and planting

machines, tractors, combines, etc.,

Small farm machinery such as lawn and garden tractors, lawn mowers,

rototiller, etc.,

Small appliances such as fans, mixers, blenders, crock pots, dehumidifiers,

vacuum cleaners, etc.,

Colmnercial machinery such as office equipment, computers and auxiliary

equipment, typewriters, calculators, vending machines, etc.,

Industrial machinery such as pumps, compressors, conveyor components,

fans, b!owers, transformers, etc.,

Fabricated metal products such as metal covered doors, frames, etc., and

Any other industrial category which coats metal parts or products under

the Standard Industrial Classification Code of Major Group 33 (primary

metal industries), Major Group 34 (fabricated metal products), Major

Group 35 (nonelectric machinery), Major Group 36 (electrical machinery),

Major Group 37 (transportation equipment), Major Group 38

(miscellaneous instruments), Major Group 39 (miscellaneous

manufacturing industries), Major Group 40 (Railroad Transportation) and

Major Group 41 (Transit Passenger Transportation); and

(B) Miscellaneous metal parts and products excludes the following items:

(i) automobiles and light duty trucks,

(ii) metal cans,

(iii) flat metal sheets and strips in the form of rolls or coils,

(iv) plastic and glass objects,

(v) magnet wire for use in electrical machinery,

(vi) metal furniture,

(vii) the exterior surface of assembled aircraft,

(viii) automobile refinishing,

(ix) customized top coating of automobiles and trucks, if production is less

than 5 vehicles per day, and

(x) the exterior surface of assembled marine vessels.
DRAFT

(3) Emission standards. No owner or operator of a facility engaged in the surface coating of

mis¢ettaneous metal parts and products may operate a coating application system subject to this

subsection that emits volatile organic compounds from any coating in excess of:

(A) 0.52 kg/1 (4.3 lb/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 5 !. 100(s) as amended from time to time, delivered to

a coating applicator that applies a clear coat;

(B) 0.42 kg/1 (3.5 lb/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator in a coating application system that is air dried or forced

wm-m air dried at temperatures up to 90 degrees C (194 degrees F);

(c)

(D)

0.42 kg/1 (3.5 lb/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator that applies extreme performance coatings;

0.36 kg/l (3.0 lb/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator for all other coatings, adhesives, fillers or sealants and

coating application systems; and

0.75 kg/1 (6.3 lb/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.!00(s) as amended from time to time, delivered to

a coating applicator which applies high performance architectural aluminum

coatings, provided that:

(i) such applicator is located at a premises which emits three thousand three

hundred thirty three (3,333) pounds of volatile organic compounds per

month or less from such applicator, and

(ii) such applicator was an existing source in Comaecticut on or before

November 1, 1994.

(4) This subsection applies to all application areas, flashoff areas, air and forced air dryers

and ovens used in the surface coating operations pertaining to miscellaneous metal parts and

products listed in subsection (s)(2) of this section. This regulation also applies to prime coat, top

coat and single coat operations.

(5) If more than one emission limitation in subsection (s)(3) of this section applies to a

specific coating, then the least stringent emission limitation shall be applied.

(6) All volatile organic compound emissions from solvent washings shall be considered in

the emission limitations in subsection (sX3) of this section unless the solvent is directed into

containers that prevent evaporation into the atmosphere.
DRAFT

(7) The provisions of this subsection apply to any premises that has actual emissions of

volatile organic compounds of fifteen (15) pounds per day or more in any one day from all

miscellaneous metal parts and products surface coating operations on such premises unless:

(a) The total potential emissions from all surface coating operations are limited by

permit or order of the commissioner to 1,666 pounds or less in any calendar

month;

4

(B) The owner or operator is and has at all times been in compliance with such

limitation since the issuance of the permit or order;

(c) The total actual emissions from all such surface coating operations have not

exceeded !,666 pounds in any calendar month since January 1987; and

(D) Notwithstanding subsections (A) through (C) of this subdivision, any surface

coating operation on such premises that emitted 40 pounds or more in any day and

that was subject to the requirements of this subsection prior to November 1, t989,

shall remain subject to the provisions of this subsection.

(8) After November 1, 1989 any premises that is or becomes subject to the provisions of this

subsection shall remain subject to the provisions of this subsection unless the owner or operator

meets the requirements of subparagraphs (A), (B) and (C) of subdivision (7) of this subsection.

(9) The owner or operator of any surface coating operation that was not subject to the

reqnirements of this subsection prior to November 1, 1989, shall have until October 1, 1990, to

comply with the requirements Of this subsection for such system.

(t 0) Notwithstanding the requirements of this subsection, an owner or operator may use, in

the aggregate, up to fifty-five (55) gallons of coatings that exceed the emission limitations set

forth in subdivision (3)(A) through (3)(E), inclusive, of this subsection at such premises for any

twelve (12) consecutive months, provided such owner or operator maintains records of such

coatings in accordance with subsection (aa) of this section. ]

Definitions. For the purposes of this section, the followin~ definitions a~

"Ablative coating" means a coating that chars when exposed to open flame or

extreme temperatures, as would occur during the failure of an engine casing or

during aerod,/namic heating. The ablative char surface serves as an insulative

barrier, protectin~ adiacent components from the heat or open flame;

"Adhesion promoter" means a very thin coating applied to a substrate to promote

wettin~ and form a chemical bond with the subsequently applied material;

"Adhesive bonding primer" means a primer applied in a thin film to aerospace

components to inhibit corrosion and increase adhesive bond stren tgXg~h-

"Aerospace high temperature coating" means a coating designed to withstand

temperatures of more than 350°F:
DRAFT

5

"Aerospace vehicle or component" means any fabricated part~?rocessed

assembly of parts, or com~leted uni_t, with the exception of electronic

components, of any aircraft includin.Kbm not limited to air lap~co ~8_~

missiles~ rockets and sl~ace vehicles;

"Air dried" means cured at a temperature below 90°C (194 deg~

Alrles~s;~ rap~!2g~hcat~on means a_~ spray application syste~ h~g_~

fluid.pressure, without compressed air_, to atomize the coating;

"Air-assisted airless S ra~t?lication" means a coatin~ a~2p_lication ~.2stem

~pressure to atomize the coating and lower p_ressure air to adjust the

sha eofthes ra attern~

"Antichafe coatinj~" means a coating applied to areas of movin~

co~_qg!~onents that may rub dm-ing_normal operations or installation;

"Antique aerospace vehicle" means an aircraft or component thereof that was

built at least 30 gears ago. An "antique aerospace vehicle" would not routinely~be_be

in corm~qercial or military service in the ca~ for which it was designe~

"A12purtanance" means any accessory to a stationary structure, including but not

limited to: batl~oom and kitchen fixtures; cabinets; concrete forms; doors;

elevators; fences; hand railings; heatin e2,_e~jpment, air conditioning e~

and other fixed mechanical equipment or stationary tools; lampposts; partitions;

R~es and pipin~ systems; rain ~utters and downs~~ fixed ladders;

catwalks; fire escapes and window screens;

"As applied" means the coml~osition of coating at the time it is applied to a

surface, including any solvent, catalyst or other substance added to the coating_b_u_t

excluding_water and exempt c~omp~

’_’Automotive-trans~?ortation !2arts" means the interior and exterior comj~onents of

motor vehicles and mobile sources;

"Baked" means cured at a temperature at or above 90°C (194°F);

"Bearing coatinp~ means a coating applied to an antifriction bearing~ bearin~g

housing or the area adiacent to such a bearing~o facilitate bearing function or to

protect base material from excessive wear. A material shall not be classified as a

"bearing" if it can also be classified as a dry lubricative material or a solid

film lubricant;

"Bonding maskant" means a temporary coatin~g used to protect selected areas of

aerospace parts from stron~ acid or alkaline solutions durin~ processing_for

bo~diny:£
6

"Business machine" means a device that uses electronic or mechanical methods to

process information, perform calculations, print or copy information or convert

sound into electrical impulses for transmission, such as,~typewriters, electronic

~ devices, calculating and accounting machines, telephone and telegraph

equipment and photocopy machines"

"Camouflage coating" means a coating used, ~ the military, to

conceal equipment from detection;

"Capture efficiency" means the ratio of VOC emissions delivered to the control

device to the total VOC emissions resulting from the miscellaneous metal and

plastic parts coating operation, expressed as a percentage;

"Caulking and smoothing compounds" means semi-solid materials that are

~ hand and are used to smooth exterior vehicle surfaces or fill cavities

such as bolt hole accesses. A material shall not be classified as a "caulking~d

smoothing compound" if it can also be classified as a sealant;

"Cavity wax" means a coatinK,_used at a motor vehicle assembl~

a~plied into the cavities of the vehicle primaril2 for the purpose of enhancing

corrosion protection;

"Chemical agent-resistant coating" means an exterior topcoat desiAned to

withstand exposure to chemical warfare agents or the decontaminants used on

these agents;

"Chemical milling maskant" means a coating that is applied directly to aluminum

components tO protect surface areas when chemically milling the component with

a__T~e I or II etchant. "Chemical milling maskants" do not include bonding

maskants, critical use and line sealer maskants, seal coat maskants, maskants that

are defined as specialty coatings or maskants used with either a TzEe I or II

etchant plus a bonding maskant, critical use and line sealer maskant or seal coat

maskant;

"Cleaning solvent" means any VOC-containing liquid, including a liquid

impregnated wipe or towelette, used in cleaning;

"Clear coating" means a colorless coating that contains binders but no pi~

and is formulated to form a transparent film;

"Coating" means a material that is deposited in a thin, persistent, uniform layer

across the surface of a substrate for aesthetic, protective or functional purposes.

Coatings include, but are not limited to, paints, primers, inks and maskants, but

exclude !?rotective oils, acids and bases~

"Coating trait" means a series of one or more coating applicators and any

associated drying area or oven wherein a coatin~pplied, dried or cured. A
"coatin~g unit" ends at the point where the coatingj~s dried or cured, orA)rior to a~y2

subsequent application of a different coating;

"Commercial exterior aerodynamic structure~primer" means a primer used on

aerodynamic comj~onents and structures that protrude from the fuseta~ch as

y~ings and attached components, control surfaces, horizontal stabilizers, vertical

~-to-bod¥ fairings, antennae and landing gear and doors :[’or the p~op~

of extended conosion l~rotection and enhanced adhesion;

7

"Commercial interior adhesive" means materials used in the bonding of~

cabin interior components. These components must meet Federal Aviation

Administration fireworthiness requirements;

"Compatible substrate primer" means one of the followin~

A primer that is comRatibie with the filled elastomeric coatin& and is

A primer that inhibits corrosion and is aRp_lied to bare metal surfaces or is

~prior to adhesive application, or

A primer that is applied to suri~aces that can be expected to come into

contact with fuel, with the exception of coatings applied to fue! tm~ks;

"Control device efficiency" means the ratio of VOC emissions recovered or

destro ev_e~hy the control device to the total VOC emissions that are introduced

into the device, expressed as a~

"Corrosion prevention compound" means a coatin~ system that provides

corrosion protection by displacing water and penetrating substra~ forming a

protective barrier between the metal suri~ace and moisture. Coatings containing

oils or waxes are excluded from this care o2,~2~

"Critical use and line sealer maskant" means a temporary coating, not covered

under other maskant categories, used to protect selected areas of aerospaceAp~

from strong acid or alkaline solutions such as those used in anodizir~

chemical milling mad processing of magnesitma, titanium or high A8 streng~

~precision aluminum chemical milling of deep cuts and aluminm~q

chemical milli~lex shapes. Materials used for repairs or to bridge gaps_

le~ribing operations are also included in this categ~

"Cr_~vogenic flexible primer" means a primer desi~rovide corrosion

resistance, flexibility and adhesion of subsequent coating systems when ext)osed

to loads u_l?~q and su~ the vield point of the substrate at c~

temperatures (-275°F and below);

"Cr~!.ryRprotective coating" means a coating that insulates cryogenic or subcooled

surfaces to limit propellant boil-o~_maintain structural inte~ritv of metallic

structures during ascent or re-entry and prevent ice formation;
8

DRAFT

"Cyanoacrytate adhesive" means a fast-setting, single component adhesive that

cures at room temperature and contains meth~ methoxymethyl or other

functional groupings of cyanoacrylate;

"Deadener" means a specialty coating applied to selected vehicle surfaces

~y for the pUlpOSe of reducing the sound of road noise in the passengc£

compartment;

"Dip coating" means a method of applying a coating to a surface bz submersion

into and removal from a coating ba__bgt_Ahth

"Drum" means any cylindrical metal container larger than 12 gallons capacit2~d

less than or equal to 110 gallons capacity;

"Dry lubricative material" means a coating consisting of lauric acid, cetyl alcohol,

waxes or other non-cross linked or resin-bound materials that act as a dry

lubricant;

"Electric dissipating coating" means a coating that rapidly dissipates a highvoltage electric charg~

"Electric-insulating and thermal-conducting coating" means a coating that

displays an electrical insulation of at least 1000 volts DC per mil on a flat test

plate and an average thermal conductivity of at least 0.27 BTU per hour-footdegree-Fahrenheit;

"Electric-insulating varnish" means a coating applied to electric motors~

components of electric motors or power transformers to provide electrical,

mechanical and environmental I?rotection or resistance;

"Electric or radiation-effect coating" means a coating or coating system

e_ngineered to interact, throu~tion or reflection, with specific regions of

the electromagnetic energy spectrum, such as the ultraviolet, visible, infrared or

microwave regions. Uses include, but are not limited to, lightning strike

protection, electromagnetic pulse (EMP) protection and radar avoidance.

"Electrostatic application" means a method of applyJ~ng coating particles or

coating droplets to a grounded surface by electrically charging such particles or

"Electrostatic discharge and electromagnetic interference coating" or "EMI

coating" means a coating applied to space vehicles, missiles, aircraft radomes and

helicopter blades to disperse static energy or reduce electromagnetic interference;

"Eleetrost~itic pre_paration coating" means a coatin ag~p_plied to at31astic part solely

to provide conductivity for the subsequent application of a primer, a topcoat or

other coating through the use of electrostatic application methods;
DRAFT

"Elevated-temperature Skydrol-resistant cormnerciaI primer" means a~primer

~p~ commercia! aircraft or commercial aircraft adapted for

military use that must withstand immersion in phosphate-ester hydraulic fluid

~_~ydrol 500b or equivalent) at the elevated temperature of 150°F for 1~0_00~

hoursl

°°EMI/RFI shield coating" means a coating_that functions to attenuate

electromagnetic interference or radio frequency interference sig~

"Epoxy polgamide topcoat" means a coati~inin eox mad ~amide

componant used to provide a hard, durable chemical-resistant finish;

~ "Etchin~ filler" means a coating that contains less than 23% solids bg~g_ht and

at least 0.5% acid b wsd_~9~ght and is used as a substitute for the aRt~lication of a

pretreatment coatin~ fol!owed by a pr~

"Exem~p_t compound" means a carbon compound excluded from the definition of

"volatile organic compound" as defined in section 22a-174-1 of the R~g~lations

of Connecticut State ~

°°Extreme high, gloss coating" means a coating that, when tested by American

Society for Testing Material Test Method D523-08, Standard Test Method for

~i~ecular Gloss, shows a reflectance of 75 or more on a 60 deg, kee meterl

"Extreme performance coatm.g, means a coating used on a metal surface where

the coated surface is, in its intended use, subject to one of the following

conditions:

Cl~ronic exposure to corrosive, caustic or acidic agents, chemicals,

chemical fames, chemical mixtures or solution~

@ K~peated exposure to temperatures in excess of 250°F, or

Repeated heavy abrasion, including mechanica! wear and repeated

scrubbing with industrial grade solvents, cleaners or scouring age_ntis

"Fire-resistant interior coating" means, for civilian aircraft, fire-resistant interior

coatings used on passenger cabin interior parts that are subject to Federal. Aviation

Administration fireworthiness requirements. For military aircraft~ fire-resistant

interior coatings are used on parts that are subject to the flammability

requirements of MIL-STD-1630A and MIL-A-87721. For sp~

"fire-resistant interior coating" means a coating subject to the flammability

re_e~uirements of SE-R-0006 and SSP 30233t

"Flexible primer" means a primer with elastomeric qualities that provides a

compatible, flexible shbstrate over bonded sheet rubber and rubber-t?j~
DRAFT

lO

’°Flight test coating" means a coating applied to aircraft other than missiles or

single-use aircraft prior to flight testing to protect the aircraft from corrosion and

to provide required marking during~jght test evaluation;

~ "Flow coating" means a non-atomized technique of aRRlying coating to a

substrate using a fluid nozzle in a fan pattern with no air supplied to the nozzle;

GL~Q~) "Fuel tank adhesive" means an adhesive that must be compatible with fuel tank

coatings and is used to bond components exposed to fuel;

H~H~)"Fuel tank coating" means a coating applied to fuel tank components for the

purpose of corrosion or bacterial Rrowth i~faibition and to assure sealant

adhesion in extreme environmental conditions;

"Heat-resistant coating" means a coating able to withstand a temperature of at

least 400° F during normal use;

~erature coating" means a coating certified to withstand a temperature

of 1000°F for 24 hottrs;

"HVLP spray~pplication" means to apply a coating using a coating application

s_vstem that uses lower air pressure and higher volume than conventional air

atomized spray systems, where the manufacturer has represented that the system

is HVLP by affixing a permanent label or through representations on the

packaging or other product literature;

°~Insulation covering" means material that is applied to foam insulation to protect

the insulation from mechanical or environmental damage;

~ ’~Intermediate release coating" means a thin coating~pplied beneath topcoats to

assist in removing the topcoat in depainting operations and to allow the use of less

hazardous depainting methods;

~ ~%acquer" means a clear or pigmented coating formulated with a nitrocellulose or

synthetic resin to dry by evaporation without a chemical reaction. "Lacquers" are

resoluble in their original solvent;

"Medical device" means an instrument, apparatus, implement, machine, gadget,

appliance, implant, in vitro reagent or other similar or related article, including

any component, part or accessory, which meets one of the following conditions:

Recognized in the official National Formulary or the United States

Pharmacopeia or an,/supplement thereto,

Intended for use in the diagnosis of disease or other conditions or irf the

~ mitigation, treatment or prevention of disease in persons or animals,
Dt~\FT

11

Intended to affect the structure or function of the body of a~person or

animal and which does not achieve its ~ntanded32u_rposes through

chemica! action within or on such body and which is not dependent upon

bein~ metabolized for the achievement of its primar,/intended pu_r~;

"Metalized epoxy coatin~" means a coating that contains relativel 12ij~g_e

quantities of metallic piKmentation for ai2pearance or added protection;

~Metallic coating" means a coating that contains more than five gLams of metal

particles per liter of coating, as applied;

"Miscellaneous metal and plastic parts" means metal andl~lastic components of

products as well as the~roducts themselves constructed either entirely_~

from raetal or plastic including, but not limited to: aerospace vehicles and

components, fabricated metal l?rodu~~lastic !~drts, small and la_g~e farina

machinery, co~ra~ercial and industrial machinery_and equipment, automotive or

transportation e~ment, interior or exterior automotive parts, construction

~nt, motor vehicle accessories, b~yycles and sportm~

recreational vehicles, extruded aluminum structural compgnents, railroad cars~

lawn and garden equipment, business machines, laboratory and medical

e_quipment, electronic equi_ mp~N!~steel drum~sdnetal pipes and small appliances;

"Mold-seal coating~ means the initial coating applied to a new mold or a repaired

mold to provide a smooth surface that~ when coated with a mold release coat;hE

prevents products from sticking_to the mold;

"Mold release" means a coatin ag~2plied to a mold surface to prevent the molded

piece from sticking_to the mold as it is removed~

~UU) "Motor vehicle" means any self-prof0elled vehicle, includin~, but not limited to,

cars, trucks, buses,_~ vmas, motorcvcles~ tanks and armored persormel

carriers;

"Multi-component coating" means a coating re~ the addition of a separate

reactive resin, such as a catalyst or harden~ before application to form an

acc_%9~table dry film;

~ ~’Nonstructural adhesive" means an adhesive that bonds nonload bearing

aerospace components in noncritical a!?plications and is not covered in anz other

s_p_ecialt,! adhesive cate~

.(XX_~2°One-component coating" means a coating that is read for a lication as

packaged for sale, except for the addition of a thinner to reduce the viscosity;

"Optical ant;reflection coating" naeans a coating with a low reflectance in the

infrared and visible wavelength ranges that is used for ant;reflection on or near

_optical and laser hardware;
12

DRAFT

"Optical coatingS’ means a coating with a low reflectance in the infrared and

visible wavelength range that is used on or near optical or laser lenses or

hardware;

~ "Overall control efficiency" means the product of the capture efficiency and the

control device efficiency2

~ °’Pan-backing_coating" means a coatinKApplied to the surface of pots, pans or

other cooking implements that are exposed directly to a flame or other heating

etementx

CC~C_C_Q~ ~Part marking" means coatings or inks used to make identif¥in~g

markings on materiats~ components or assemblies. These markings may be either

permanent or tempor~_y~

~ "Plastic part" means any piece or combination oft?ieces of which at least one

has been fomxed from one or more resins. Such pieces may be solid, poro~

flexible or ri~parts" do not include parts made of fiberKlass or

composite materials;

EE~E~E_) "Prefabricated architectm-al component coating" means a coating applied to

prefabricated metal parts and products that are to be used as architectural

a~l?urtenances or structures and that are detached from the structure when coated

in a shop environment;

Pretreatment coating means a coatlng, containing at least 0.5 percent acid b_y

weight, applied directly to a metal surface to provide surface etching, adhesion

and ease of stripping;

~ "Primer" means a coating applied to prevent corrosion, provide protection or

provide a surface for adhesion of subsequent coatings;

(HHHH) "Radome" means the nonmetallic protective housing for electromagnetic,

transmitters and receivers such as radar or electronic countermeasures;

"Rain erosion-resistant coating" means a coating or coating system used to.protect

the leading edges of parts, such as flaps, stabilizers, radomes or en~ne inlet

nacelles against erosion caused by rain impact during flight;

JJ(~ "Related cleaninK" means the removal of uncured coating& coating residue and

contaminants from:

miscellaneous metal and plastic parts prior to the application of coating~

miscellaneous metal and 9tastic parts between coating applications~9£or

transfer lines, storage tanks, spray booths and coatin ag~2plication
DRAFT

13

"Repair coating" means a coating used to recoat portions of a~roduct that

has sustained mechanica! damage to the coating following normal -~iAg

O_l~erations;

. LL(_L_~L_~ "Resin" means any of numerous ~ similar polymerized synthetics

or chemically modified natural materials includin~lastic materials such

~vin_vjgxkl _polystyrene and ~¥1ene and thermosetting materials such as

~oxies and silicones;

~_IVIMMM) "Resist coating" means a coating that is applied to a plastic part before

metallic plating to prevent deposits of metal on portions of the ~ a.Ka~;

~5~ "Rocket motor nozzle coating" means a catalyzed epo~ system used

in elevated temperature applications on rocket motor nozzles;

LO_Q~Q~ _"Roll coating" means a coatingk~aethod using a machine that applies coating to

a substrate by continuously transferring ~~h a set ofo~

rotating rollers;

"Rubber-based adhesive" means a quick-setting contact cement that provides a

strong, yet flexible bond between two substrates that ma3~ be of dissimilar

materials;

~Q_Qg_) "Safety-indicating coating" means a coating that changes in a ph_¥sical

characteristic, such as color to indicate unsafe conditions;

.(~) "Scale inhibitor" means a coating that is applied to the surface of a. mp__m_.prior

to thermal processing to i~ibit scale formation;

"Screen print ink" means an imk used in screen ~ processes during

fabrication of decorative laminates and decals;

~TT~ "Sealant" means a material used to prevent the intrusion of water, fuel, air o~

other liquids or solids from certain areas of aerospace vehicles or components;

"Seal coat maskant" means an overcoat a.t?plied over a maskant to improve

abrasion and chemical resistance duringdp_roduction operations;

"Self-.priming topcoat" means a topcoat that is applied directly to an

_uncoated aerospace vehicle or component for corrosion prevention, envirom~ental

protection or functional fluid resistance. More than one layer of identical coating

fornmlatio~ may be _applied to the vehicle or component;

£wwww) ’_’Shock-free coatinj~" means a coatingJ4t2plied to electrical components to

pj’otect the user from electric shock. The coating.provides for low capacitance

and hij~h resistance and resists breakinA down under hi~
14

DRAFT

XX(~X~) "Silicone insulation material" menus an insulating material at2plied to exterior

metal surfaces for protection from high temperatures caused b~heric

friction or engine exhaust. "Silicone insulation materials" differ from ablative

coatings in that "silicone insulation materials" are not sacrificial.;

~ "Silicone-release coating" means any coating.that contains silicone resin and is

intended to prevent food from sticking to metal surfaces such as baking pans~

"Solar-absorbent coating" means a coatingthat has as its primrose the

absoI~tion of solar radiation;

(.AAAAA_) "Solid-film lubricant" means a very thin coatin~ consisting_of a binder s2stem

containing as its chief pigment material one or more of molybdemmx disulfide,

~, polytetrafluoroethylene or other solids that act as a dry lubricant

between laying surfaces;

(~BBBBB) ]’Space vehicle" means a man-made device, either mamied or unrn~_~_~ed

_designed for operation beyond earth’s atmosphere. This definition includes

integral equipment such as models, mock-ups, proto es molds ~ s toolin

hardware iackets and test coupons. "Space vehicle" includes auxiliary equipment

associated with test, transport and stora.g~, which throug~h contamination can

compromise the space vehicle performance;

!~CCCCC) ’_’Specialty coating" means a coatinR that, even though it meets the definition

of a primer, topcoat or self-priming topcoat, has additional perfbrmance criteria

beyond those of primers, topcoats and self-priming topcoats for specific

applications. These performance criteria may include, but are not limited to,

temperature or fire resistance, substrate compatibility, antireflection~ tern_ orp_Q[~

protection or marking, sealing, adhesion or enhanced corrosion protection.;

£DDDDD) "__Specialized function coating" means a coating that fulfills extremely

_specific engineering requirements. A "specialized function coating" is limited in

application, characterized by low volume usage and is not able to be cateRorized

as any other coatin~ in Table 20 s -(~k~

(EEEEE)"Stencil coating" means an ink or a coating that is rolled or brushed onto a

_template or stamp to add identifying letters or numbers to metal parts or products;

"Structural autoclavabte adhesive" means an adhesive used to bond loadca_q_gg_yin~ aerospace components that is cured by heat and pressure in an autoclave;

(~GGGGG) "Structural nonautoclavable adhesive" means an adhesive cured under

ambient conditions that is used to bond load-carryin~ aerospace components or

other critical fimctions, such as nonstructural bonding in the proximity of engines;

(.I-IHHHH_I "Temporary protective~" means a coatingARplied to provide scratch

or corrosion protection during manufacturing__, storaRe or transportation.
DRAFT

15

"Temp_ora~ry protective coatings" do not include coatin%~~ainst

strong acid or alkaline solutions;

"Texture coat" means a coating that is ~Rplied to a plastic part which, in its

finished form~ consists of discrete raised s_pots of the coating;

~.lJJ) "Textured finish" means a roug_h surface j~roduced by s~ and splattering

l_~l?S of coatin~ ont~reviousl a22gp2olied coating;

fKKKKK) "Thermal control coating" means a coating formulated with ~ecific thelraal

conductive or radiative ~erties to pen~ait temperature control of the substrate;

.Lf~J_~ °’Touch-up coating" means a coating_used to cover minor coating

imperfections a_~ after the main coatinKg_~

~_MMMMM) "Transfer efficiency" means the portion of coating, solids that adheres to

the metal or plastic surface during the a~Rplication ~~ressed as a

~e of the total volume of coating solids delivered ~ ~

(NNNNN) "Translucent coating" means a coating which contains binders and

R~ment and is formulated to form a colored~ but not opal.

fOOOOO) ’~Vacuum-metalizing_coating" means an undercoat applied to a substrate on

which metal is deposited or an overcoat applied directly to a metal film;

"Wet fastener installation coating" means a primer or sealant applied by

~ brush~ or daubin to fasteners that are installed betbre the coating~

cured" and

~Q_Q_Q_Q_Q) ~’Wing coating" means a corrosion-resistant topcoat that withstands the

flexin, of aircraft win~

_Applicabilit,/.

~ Except as provided in subdivision (7) of this subsection, the provisions of this

subsection ~ to the owner or Qperator of any miscellaneous metal and plastic

l_~arts coatintg unit:

~_~ That is subject to this subsection prior to Januar~ or

For which the owner purchases for use at the premises 855 gallons or

more of coatings_ and cleaning solvents in a~gL~zate per rollin~ 12-month

12eriod.

.An owner or operator subject to this subsection shall:

For an existing miscellaneous metal and plastic parts coatin~

with the requirements of this subsection no later than January~l~ 2013 or
16

DRAFT

For a miscellaneous metal and plastic parts coatin~ unit that commences

operation after January 1, 2013, com_p~l with the requirements of this

subsection upon commencing_operation.

Any owner or operator subject to this subsection shall remain subject to this

subsection.

~) Exce t~EL~provided in subdivision (7) of this subsection, on and after January 1, 2013, no

owner or o~perator shall apply any coatinR, incl_usive of any VOC-cuntaining material added to

the origjnal coatin~¥ the manufacturer, unless the owner or operator controls

emissions of VOCs in accordance with sub ara ra h A B C) or (D) of this subdivision. If

more than one emission limit or emission rate aR!~lies in a~particular situation, then the least

restrictive limit or emission rate shall apply. An owner_or operator shall control the emission of

VOCs~ as follows:

Use only coatings that have an as applied VOC content no ~reater than the

a~plicable level in Table 20(s)-l, 20~)-3, 20(s)-4, 20(s~-6a or

For a coatinR unit, use a combination of low-VOC coatings and add-on air

pollution control equipment to achieve a VOC emission rate no greater than the

_applicable level in Table 20(s)-7, 20(s)-8, 20(s)-9, or 20(s)-I 0,

Install, operate and inaintain accordin~ to the manufacturer’s recommendations

air pollution control equipment with an overall control efficiency of at least 90%.

An alternative means, achieving a level of control equivalent to subparagraph (A)~

B~ (C) of this subdivision, requested from and approved by the commissioner

in accordance with subsection (co) of this section.

L~) Application methods. Except as provided in subdivision (7) of this subsection, an owner

~erator shall not aRplg a VOC-cuntaining coating to a miscellaneous metal and plastic part

unless the coating is applied by one of the methods identified in subparagraphs (A) through (I) o_f

this subdivision using equipment operated in accordance with the specifications of the equipment

manufacturer:

Electrostatic application;

Flow coating_;

Dip coating;

DLD~ Roll coating;

~) HVLP spray application;

Airless spray application;
17

Air-assisted airless spray~p~lication;

Hand al;Zl~licationkg~

An,/other coating_aaEiplication method capable of achieving_a transfer efficiencx

equivalent to or better than that provided b?d HVLP s_pra,/application. Any owner

~9r usin~ an application method pursuant to this sub aap_~w:~gh shall

maintain records demonstrating the transfer efficiency achieved.

Work practices. Each owner or op_erator shall use the following wo__w_o2g~k ractices:

New and used VOC-containing coating, or cleaning solvent, includi~

mixed on the premises, shall be stored in a nonabsorbent, non-leakii~g container.

Such a container shall be kept closed at all times except when the container is

be’m~d_, emptied or is otherwise actively;

.~l~ills and leaks of VOC-containing coating or cleaninN solvent shall be

minimized. An,/leaked or spilled VOC-containin.g~ or cleaning solvent

shall be absorbed and removed immediatel,/;

Absorbent aRplicators, such as cloth and a_~IkC~__which are moistened with a VOCcontaining coating or solvent, shall be stored in a closed, nonabsorbent, nonleaking,container for dis~posal or rec,/cling; and

VOC-containin~and cleaning, solvent shall be conveyed from one

!ocation to another in a closed container or ~

~) Notwithstandi~quirements of this subsection, an owner or operator comlgyjn_g

with this subsection b,/ operating under a valid.permit or order issued pursuant to subsection

(cc)(2) or (cc)£~) of this section shall continue to oEerate according to the terms of such permit or

order.

Exemptions and exceptions.

Exce~rovided in subdivision_(8) of this subsection, the requirements of this

subsection shall not apply to an.v of the following activities, and the VOC

emissions resultinj~ from the following activities shall not be included in

detemainations j0ursuant to subdivision (_~) or~)(G) of this subsection:

Coating and cleaning~ect to one of the following subsections of this

section: ~ and (hh) throu h.g_h_L~

Coating applied in an automotive refinishin~eration and related

cleaning~

Coating and associated s~rface p_~l~aration and cleanup subiect to section

22a- 174-41 of the Regulations of Connecticut State Agencies,
18

DRAFT

Coating applied to test materials, test panels and coupons in research and

development, quality control or performance testing~

Coating applied in a shipbuilding and repair operation~provided that the

9peration is subject_ to and o_perating in compliance with 40 CFR 63

~t2plied to space vehicles and related cleaning,

Coating_gl?I?lied to antique aerospace vehicles and related cleaning,

Coatin.g applied with a hand-held aerosol can,

Adhesive, sealant, adhesive 1)rimer or sealant primer regulated by section

22a-174-44 of the ReKulations of Connecticut State A~encies~

~ ~ control or inspection dyes applied to metal parts,

,x~ Use of coatings containing VOC at concentrations less than 1.0 percent by

Use of cleaning solvents containing VOC at concentrations less than 5.0

percent by weight.

The requirements of subdivisions (3) and (4) of this subsection shall not appl7~

the application of any of the following coatings to metal parts:

(j) Stencil coating,

i@ Safety-indicating coating,

~ Solid-film lubricant,

i~) Electric-insulating and thermal-conducting coating~

~g) _M_~Knetic data storage disk coating,

vfyj) Plastic extruded onto metal parts to form a coating~gy

vfX~ Powder coating.

The requirements of subdivision (3) of this subsection shall not a~

application of any of the following coatings to plastic parts:

Touch-up and repair coating,

Stencil coating applied on a clear or transparent substrate,
DRAFT

19

~ Clear or translucent coating:

~2) Reflecf~ve coatin a lied to a h~g~

Mask coatin~g less than 0.5 millimeter thick aRl?lied to an area less than 25

s~uare inches~

EMI/RFI shield coatinx~

Any heparin-benzalkonim~a chloride (HBAC)-containin~ coati~

to a medical device, provided that the total of all HBAC-containing

coatings used at a facility does not e~~year or

~ Powder coating:

The requirements of subdivision (3) of this subsection shall not al~pLly to the

application of any of the followin~utomotive-trans~9ortation and

business machine parts:

~(~ Vacuum metalizin~

~) Gloss reducer

~ Texture coat~

~) Adhesion ~,.

~ Electrostatic 12Le_paration coating

. v(xj) Resist coating:

~

Stencil coating~K

~ Powder coating:

The requirements of subdivisions (3) an_d (4) of this subsection shall not apply to

the application of any of the following specialty coat~s to an aerospace vehicle

or comagonent:

~ Touch-up coa~

Aerospace coatinj~ that the United States Department of Defense has

designated as classified information in accordance with 32 CFR 2001.

The requirements of subdivision (4_) of this subsection shall not apply to the

followinK activities:
DRAFT

~ _Application of touch-up and repair coatin~g__tg~ metal ~

i~ Application of textured finish to metal parts~

~ Application of powder 9oatin tg392

Plastic aRg~

Automotive-transportation plastic parts, or

Business machine ~

Airbrush application of coating to metal or plastic parts using no more

than five gallons of coating~

~ Use of air pollution control equipment to comp_lly with subdivision (3) of

this subsection, or_

Application of specialty coating~ listed in Table 20(s)-6a of this

subsection.

20

An o~vner or operator with total potential VOC emissions from all miscellaneous

metal and plastic parts coatin~ emissions from related cleaning, limited

by permit or order of the commissioner to 1,666 pounds or less in any calendar

month, shall not be subiect to the requirements of subdivision (3) of this

subsection, provided that the owner or operator operates in compliance with such

a permit or an order.

An owner or ot~erator may use in aggregate in any 12 consecutive months no

more than 55 gallons of miscellaneous metal or plastic parts coating or coating

that exceed the VOC content limits or emission limits of subdivision (3) of this

subsection provided the o~vner or operator maintains records of non-compliant

coating use.

An owner or operator controlling emissions as provided in subdivision (3) of this

subsection is exempt from any obligation to comply with subsection (bb) of this

section.

~uirements of subdivision (3) of this subsection shall not apply, upon

r__equest to and approval by the commissioner. Any request for approval shall be

made in writing to the commissioner and shall include a description of the

noncompliant coating and its VOC content, an explanation of why the

noncomptiant coating is necessary, the aggregate amount in gallons or pounds of

noncompliant coating use anticipated in a 12-month period and the frequency of

use of the noncompliant coating.
DRAFT

21

_Records.

An owner or operator shall maintain records of information sufficient to

determine compliance with the applicable reo~irements of this subsection,

including, at a minimum, the information described in sub ~at?_~gg~ hp~h~ of this

subdivision. All such records shall be:

~i~ Made available to the commissioner to inspect and copy u~on request, an_d

~ Maintained for five years from the date such record is created.

An owner or operator shall maintain records of the foltowin~ information for each

calendar month:

_Name and description of each coating and cleanin~ sol~.

VOC content of each coating and cteanin~~ and the

associated calculations,

~ VOC content of each coating or cleanin£ solvenL as supplied,

~2) The amonnt of each coating and cleaning~solvent:

~) Purchased,~or

~ Actually us_q~d~ed

A Material Safet~Sheet Environmental Data Sheet, Certified

Product Data Sheet or an equivalent data sheet for each coatin~ and_

cleanin~

v~yj) Documentation of control device efficianc~ture efficiency, if

a~p.pticable, usin~ an~a_p~licable EPA reference method or attemate method

~roved by the commissioner, and

Date and ty~pe of maintenance performed on a_k2oollution control

~RPlicable.

~ Any owner or operator who does not meet the applicability thresholds provided in

subdivision/2)(~ of this subsection shall maintain either material l?urchase or

actual usage records to verifx that this subsection does not aRply to such owner or

operator.

An owner or operator opera~ursuant to an excet?tion or exem_ption in

subdivision (7) of this subsection shall maintain records sufEcient to verify the

applicability of the exception or exemption.
DRAFT

Compliance procedures.

The VOC content limits of Table 20(s)-1, 20(s)-2, 20(s)-3, 20(s)-4, 20(s)-5, ~

6a or 20(s)-6b apply_to the volume of coatin asg__gf!~pplied, determined usin tg~he

following equation:

VOC Content = (Ws - Ww-Wes)/(Vm - Vw - Ves)

Where: Ws = weight of volatile compounds in grams

Ww = weig~ht of water ingrams

Wes = weight of exempt compounds in grams

Vm = volume of coating in liters

Vw = volume of water in liters

Ves = volume of exempt compounds in liters

The VOC emission rate limits of Table 20(s_)-7~ 20(s)-8, 20(s)-9, or 20(s)-10 apply

to the mass of VOC emitted per volume of coating_solids, as applied.

To dete~nine the properties of a coating~ components thereof in order to

perform the calculations required pursuant to subparagraph (A) of this subdivision

6r to verify calculations based on the manufacturer’s formulation data, the VOC

and solids content of all coatings shall be determined using 40 CFR 60, Appendix

A, Reference Method 24 or an equivalent method. In the case of a dispute; the

VOC content determined using Reference Method 24 shall control, unless a

person is able to demonstrate to the commissioner’s satisfaction that the

manufacturer’s formulation data are correct.

For red, yellow or black automotive coatings~ except touch-up and repair coatings,

the applicable VOC content limit or emission rate shall be the limit of Table

20(s)-3 or 20(s)-9, as applicable, multiplied by 1.15.

Where a VOC content limit or emissions rate is provided in metric units a~d

equivalent English units, the limit or rate in metric units defines the standard. The

English units are provided for information onl~

A miscellaneous metal or plastic parts coating shall be defined and cateKorized

based on the manufacturer’s representations as set out on the container or label or

in information provided by the manufacturer of such a miscellaneous metal or

~arts coating.

~ Limitations on potential to emit; modification of permits or orders issued j~rior to January

j 2013. An owner or operator issued a permit or order prior to January 1, 2013 pursuant to

former section 22a-174-20(s)(7) of the Regulations of Connecticut State Agencies may:

Cuntinue after January 1, 2013 to conduct miscellaneous metal parts coating in

compliance with such a permit or order; or
23

_Submit a request to the commissioner to revise or modify the order or pemait to

include an3, miscellaneous plastic and metal~ at the premises in the

monthly limit of 1,666 pounds of V. O~rovided in subsection (s)(7)(G) of this

section. Such a request shall be submitted no later than January 1 2~013.

Metal

Coating Catego~

General one-component

General multi-component

Camouflage_

Electric-insulating varnish

Etching filler

Extreme hi~

Extreme performance

Heat-resistant

~erfonnance

architectural

~h temperature

Metallic

Mold-seal

Pan backing

Prefabricated architectural

multi-component

Prefabricated architectural

one-component

Pretreatment coating

R~pair and touch-up

Silicone release

Solar-absorbent

Vacuum-metalizing

Dmm coating, k~

exterior

Drum coatin ng.,A~ ~

imerior

Drum coatin~

reconditioned, exterior

Drum coating=

reconditioned, interior

Table 20(s)-1

Parts Coating VOC Content Limits

Air Dried

VOC/liter lbs VOC/

coatin~

gal cg~t~.~g340 2.~8

34~0 2.~8

42__Q0 3 .~5

420 3.5

420 3.5

420 3.5

420 3.5

420 3.5

74~0 6.~2

420

420

420

420

42__0_0

420

420

420

420

420

340

420

420

500

3.5

3.5

3.5

3.5

3.~5

3.5

3.5

3.5

3.5

3.5

2._~8

Baked

~ VOC/liter lbs VOC/

28_~0

28_~0

42~0

420

420

360

360

36O

74~0

420

420

420

420

28_ 0

420

360

420

360

420

34~0

50__Q0

gal coatin~

2.~3

2.~3

3.~5

3.5

3.5

3.0

3.0

3.0

6.~2

3.5

3.5

3.5

3.5

2.~3

3.5

3.0

3.5

3.0

3.5

2.~8
24

DRAFT

Table 20(s)-2

Plastic P_.arts Coating ,_V_OC Content Limits

~Coating C~.~g~.~

General one-component

General multi-component

Electric dissipating coatings and shockfree coating

Extreme pertbrmance multi-component

Metallic

Mold-seal

Multi-colored coating

_Qptical coating

Vacuum-metalizing

g VOC/liter coating

28__~0

42__Q0

80~0

42__Q

42__00

76~0

68__Q0

80_~0

800

lbs VOC/gal coati.n.g_

2.~3

3.~5

6.~7

3.~5

6._3_3

5.~7

6.~7

6._27

Table 20(s)-3

~p~0motive-Transportation Plastic Parts Coating VOC Content Limits

Coating Category g V6C/liter coatin~ lbs VOC/gal coating

I.~ bake coatings - interior and exterior parts

Flexible primer 54~o 4.5

Non-flexible.primer 420 3.5

Base coat 52O 4.3

Clear coat 48__QO

Non-basecoat/clear coat 52~o

II. Low bake!air dried coatings - exterior parts

Primer 580 4.8

Basecoat 600 5.0

Clearcoat 54_~0

Non-basecoat/clearcoat 600 5.0

III. Low bake/air dried coatings - interior 6o_9_0

IV. Touchup and~epair coating 62_._0_0

Table 20(s)-4

Busines~._Machine Plastic Parts Coating

Coating Category

I_. Primers

III. Texture coat

IV. F______~og coat

V. Touchup and~

VOC/iiter coai~ng

350

350

350

260

350

VOC Content Limits

lbs VOC/gal coating

2.9

2._22

2.__~9
DRAFT

25

Table

Motor Vehicle Materials VOC Content Limits

Coating Catego ,ry._

Motor vehicle cavity wax

Motor vehicle sealer

Motor vehicle deadener

Motor vehicle as~ket sealing

material

Motor vehicle underbody coating

Motor vehicle trunk interior coating

Motor vehicle bedliner coating

Motor vehicle lubricating wax!compound

650

65~0

65O

200

65_Ao

65__0_

20__~0

70~0

5._A4

5._A4

5._A4

1._27

5.__A4

1.~7

5_._8

_CgaAjng .typ,, o

Ablative coating

~dhesio prom0ter

Adhesive bonding_primers:

Cured at 250°F or below

Cured above 250°F

Adhesives:

Coma:aercial interior adhesive

Cyanoacrylate adhesive

Fuel tank adhesive

Nonstructural adhesive

Rocket motor bonding adhesive

Rubber-based adhesive

Structural autoclavable adhesive

Structural nonautoclavable adhesive

Aerospace high-temperature coating

Antichafe coating

Bearing coating

Caulking m~d smoothing co~!~ounds

Chemical agent-resistant coating

Clear coating

Commercial exterior aerodynamic structure.primer

Compatible substrate primer

Conosion prevention compound

Cryogenic flexible primer

~ctive coating

Dry lubricative material

Table 20(s)-6a

Aerp.~p~ce Special~ ~oatin~ VOQ ~_ontent Limits

60__Q

85~0

t030

760

620

36_~0

89O

850

85_~0

85_~0

660

620

850

550

720

650

780

71_~0

64~5

6OO

880
26

DRAFT

Electric or r~diation-effect coating 800

Electrostatic discharge and electromagnetic interference 80_._Q0

Elevated-temperature Skydro!-resistant commercial primer 740

E ox ol amide topcoat 660

Fire-resistant interior coating 80 0

Flexible prime_r 64_ 0

F_~g_ht-test coating~2

Missile or sinNle use aircratt

All other 840

Fuel-tank coating 72__Q0

Insulation coverinR 74 0

Intelmediate release coating

830

Maskants2

B__onding maskant

Critical use and line sealer maskant

Seal coat maskant

Metallized e_~ 740

Mold release 780

_Optical ,anti-reflective coating 750

Part markin~ 85_ 0

Pretreatment coating 780

Rain erosion-resistant coating 85O

R__ocket motor nozzle coatinR 660

Scale ir~hibitor 88 0

Screen print ink 84_~_0

Sealants:

Extrudable/rollable/brushable sealant 280

Sprayable sealant 600

Silicone insulation material 85 0

Solid film lubricant 88~0

Specialized function coating 890

Te___mporar¥ protective coating 320

_Thermal control coating 800

Wet thstener installation coating 675

_Win~ coating 85~0

Table 20(s)-6b

AeEospace Coating VOC Content Limits

Coati_ng type

Primer - general aviation rework facilities

Exterior primer - large commercial aircraft components

Exterior primer - fully assembled, large commercial aircraft

Primer

g VOC/I.!te__r coating

540

650

650

35__0_0

42~0
DRAFT

~eneral aviation rework thcilities 54~0

Selfzpr~coat 42_~0

~opcoa~eneral aviation rework facilities 54~0

~y_pe I chemical milling_maskant 62~2

~ ch. emical milling maskant !6~0

27

Table 20(s)-7.

Metal Parts Coating V0~ Emission Rate Limits

~C_o~fir~g ~at_egg~

General one-component

General multi-component

Camouflage

Electric-insulating varnish

Etching filler

_Extreme high-gloss

Extreme performance

Heat-resistant

H_jgh_perfon~ance architectural

High temperature

Metallic

Mold-seal

Pan backing

Prefabricated architectural multicomponent

Prefabricated architectmal onecomponent

Pretreatment coatin~

Silicone release

Solar-absorbent

Vacuum-metalizing

Dram coating, new, exterior

_)rum coating, new, interior

Dram coating, reconditioned, exterior

Drum coatin~ reconditioned interior

Air Dried

KVOC/ lb VOC/

54~0 4.5~2

540 4.52

80_~0 6.67

80~0 6.67

80_~_0 6.67

800 6.67

800 6.67

80__Q0 6.67

4560 38

800 6.6~7

800 6.67

800 6.67

800 6.67

80__QO 6.6~7

800 6.6_~7

80__QO 6.6_~7

80~0 6.67

800 6.6~7

540 4.5_~2

80_~_0 6.6~7

1170 9.78

Baked

g VOC/ lb VOC/

liter solid_ ~ s_ ~

40~0 3.3~5

40~0 3.35

80~0 6.

800 6.6~7

800 6.67

610 5.06

61_~0 5.0_~6

610 5.O6

4560 38

80__0_O 6.67

80_.~0 6.67

8~O____QO6.6~7

_Q 6.67

40___QO 3.35

40~0 3.3~5

80_~0 6.6_~7

80_~_0 6.67

610 5.06

80~0 6.67

54~0 4.5~2

8 6.6__27

80~0 6.67

1170 9.78
28

DRAFT

Table 20(s)-8

Plastic ~’.a_.r..~s Coating VQ_C Emis_~s_ion_ R_.gt__e__L.i_mits

C o a t in ~_C_.~.t_eg o ,r V

General one-component

General multi-component

Electric dissipating coatings and shock-free

coatin, g~

g.._V.~_C_/liter solids

40O

80~_Q0

I b_~. V o C/ga_l_ ~.q lid. s

3.35

6.67

8960 74.7

performance multi-component

Metallic

80 0

52

3040

8960

8960

Mold-seal

Multi-colored coatings

Optical coatingf!

Vacuum-metatizing

6.67

6.67

43.7

25.3

74.7

74.7

Table 20(s)-9

Autom0tive-Transp.?ytation Plastic Parts Coa!i_n.g_VOC Emission Rate Limits

Coatin Category I g.yOC/liter solids~

I.~ bake coatin~_s - interior and exterior parts

_Flexible primer

Non-flexible primer

Base coat

Clear coat

Non-basecoat/clear coat

II. Low bake/air dried coatings - exterior parts_

Primer

Basecoat

Clearcoat

Non-basecoat/clearcoat

III, Low bake/air dried coatings - interior parts

IV. Touch-t~air Coating

1390 1t.5~

80~0 6,67

1240 10.34

1050 8.76

1240 10.34

1660 13.8

187Q 15.59

1390 11.58

1870 15.59

1870 15,59

2130 17.72

Table 20(s)-10

_~Business _]~ l_a__chine Plas~i_~q Parts Coating VOC

Coating Category

I. Primers

III. Texture coat

V. Touchup and repaint

g_V.._OC/liter solids__

570

57~0

57~0

38~0

57~0

Emission Rate Limits

_!~_ VOC/g~l..solids

4.80

4.80

4.80

3.14

4,80
DRAFT

Sec. 2. Subdivision (1) of subsection (aa) of section 22a-174-20 of the Regulations of

Connecticut State Agencies is amended to read as follows:

(aa) Record keeping requirements and test methods.

(1) The owner or "operator" of any premise subject to the provisions of subsections (nr)

through [(s)] _CO inclusive and subsection (v) of section 22a-174-20 shall maintain daily records

of all coatings and diluents used. Such records shall be kept for each individual machine,

operation or coating line. The records must contain the information required below.

(A) description of the coating including the coating name and the coating density in

pounds per gallon;

29

(B) "volatile organic compound" content by weight;

(C) water and exempt volatile organic compound content by weight;

(D) non-volatile content by volume and by weight;

(E) amount of each coating used in gallons;

(F) total amount of diluent used for each coating in pounds and in gallons.

Sec. 3. Subdivisions (2) and (3) of subsection (cc) of section 22a-174-20 of the Regulations

of Connecticut State Agencies are amended to read as follows:

[(cc)(2)] .(2~ The implementation of an alternative emission reduction ptma instead of

compliance with the ["]emissions limitation["] prescribed in any one of subsections (m) through

(v): [inclusive and] (ee) or.R_rd~~ of this section must be expressly approved by the

["Commissioner"] cormnissioner through the issuance of a permit or an order in accordance with

the provisions of section 22a- 174-12 of the Regulations of Connecticut State Agencies and

approved by the ["administrator"] Administrator in accordance with the provisions of 42

[U.S.C.] USC 740!-7642. After approval, any emissions in excess of those established for each

emission source under the plan will be a violation of these regulations.

[(cc)(3)] 3~) Where it can be shown to the satisfaction of the ["Commissioner"] conmaissioner

that an emission source cannot be controlled to comply with ~ one of subsections (m) through

(v)~ [inclusive and] (ee) or (fi) throuKh (kk) of this section for reasons of technological and

economic feasibility, the ["Commissioner"] commissioner may by permit or order accept a lesser

degree of control upon the submission of satisfactory evidence that the ["]stationary source["]

owner has applied ["]Reasonably Available Control Teclmo!ogy["] and has a plan to develop the

technologies necessary to comply with [tlre above subsections] the applicable subsection of

subsections (m) throu~gh (kk) of this section and such action is approved

by the ["administrator"] Administrator in accordance ~vith the provisions of 42 [U.S.C.] USC

7401-7642.
DRAFT

Sec. 4. Section 22a-174-20(ii)(3)(A) of the Regulations of Connecticut State Agencies is

amended to read as follows:

30

The requirements of this subsection shall not apply to the use of cleaning solvent

as follows:

(i)

(ii)

(iii)

(iv)

(v)

(vi)

(vii)

(viii)

(ix)

(x)

(xi)

(xii)

(xiii)

In janitorial cleaning,

At an aerospace manufacturing and rework operation or a wood furniture coating

operation in accordance with an order or a permit issued pursuant to sections 22a174-32(e) and 22a-174-20(cc) of the Regulations of Connecticut State Agencies,

To perform general solvent cleaning in accordance with an order issued pursuant

to section 22a-174-20(ee) of the Regulations of the Cormecticut State Agencies,

At any aerospace manufacturing and rework facility, provided that cleaning

solvent is used in accordance with the requirements of 40 CFR 63.744, inclusive

of exemptions,

As surface preparation or cleanup solvent in accordance with section 22a-174-44

of the Regulations of Connecticut State Agencies,

Where the cleaning solvent is regulated pursuant to section 22a-174-40 of the

Regulations of Connecticut State Agencies,

To perform industrial solvent cleaning where such cleaning or cleaning solvent is

subject to one of the following subsections of this section: (/) through (y), (ff)

tkrough (hh), or (jj),

In cleaning, including surface preparation prior to coating, necessary to meet a

standard or specification issued or approved by the United States Department of

Defense, Federal Aviation Administration or other federal government entity.

Any person claiming exemption pursuant to this clause shall maintain records of

the standard or specification,

Associated with research and development,

Associated with quality control or laboratory testing[,] of coatin~

adhesives~

Associated with medical device manufacturing,

Associated with pharmaceutical manufacturing,

That exceeds the applicable limit of subdivision (4)(A) of this subsection where

the quantity used does not exceed 55 gallons per any twelve-month rolling

aggregate. Any person claiming exemption pursuant to this clause shall record
DRAFT

31

and maintain monthly records sufficient to demonstrate compliance with this

exemption, or

(xiv) That exceeds the applicable limit of subdivision (4)(A) of this subsection, if

approved by the commissioner and the Administrator, Any request for approval

shall be made in writing to the commissioner and Administrator and shall include

a description of the cleaning solvent and its VOC content, m~ explanation of why

the cleaning solvent is necessary, quantification of the amount of the VOC that

will be emitted as a result of the use of the noncompliant cleaning solvent and the

time period over which the noncompliant solvent will be used.

Sec. 5. Section 22a-174-20 of the Regulations of Connecticut State Agencies is amended by

the addition of new subsection (kk), as follows:

~EW)

(kk) Pleasure craft coatings

(1) Definitions. For the purposes of this section, the following definitions apply:

(A) "Airless spray application" means a coating spray application system using high

fluid pressure, without compressed air, to atomize the coating;

(B) "Air-assisted airless spray application" means a coating spray application system

using fluid pressure to atomize the coating and low pressure air to adjust the shape

of the spray pattern;

(0 "Antifouliug coating" means a coating applied to the underwater portion of a

pleasure craft to prevent or reduce the attachment of biological organisms;

(D) "Antifouling sealer or tie coat" means a coating applied over biocidal antifouling

coating for the purpose of preventing release of biocides into the envirorm~ent or

to promote adhesion between an antifouling coating and a primer or another

antifouling coating;

(E) "As applied" means the composition of coating, excluding water and exempt

compounds, at the time it is applied to a surface, including any solvent, catalyst or

other substance added to the coating;

"Capture efficiency" means the ratio of VOC emissions delivered to the control

device to the total VOC emissions resulting from pleasure craft coating and

related cleaning, expressed as a percentage;

(G) "Control device efficiency" means the ratio of VOC emissions recovered or

destroyed by the control device to the total VOC emissions that are introduced

into the device, expressed as a percentage;
DRAFT

(i)

(J)

32

"Electrostatic application" means a method of applying coating particles or

coating droplets to a grounded surface by electrically charging such particles or

droplets;

"Exempt compound" means a carbon compound excluded from the definition of

"volatile organic compound" as defined in section 22a-174-1 of the Regulations

of Connecticut State Agencies;

"Extreme high-gloss coating" means a coating that, when tested by American

Society for Testing Material Test Method D523-08, Standard Test Method for

Specular Gloss, shows a reflectance of 90 or more on a 60 degree meter;

(K)

(L)

(M)

"Finish primer or surfacer" means a coating applied with a wet film thickness of

tess than I0 millimeters prior to the application of a topcoat for purposes of

providing corrosion resistance, adhesion of subsequent coatings, a moisture

barrier or promotion of a uniform sur~[‘ace necessary for filling in surface

imperfections;

"Flow coating" means a non-atomized technique of applying coating in a fan

pattern to a substrate using a fluid nozzle with no air supplied to the nozzle;

"High build primer or surfacer" means a coating applied with a wet film thickness

of I0 millimeters or more prior to the application of a topcoat for pmlaoses of

providing corrosion resistance, adhesion of subsequent coatings, a moisture

barrier or promotion of a uniform surface necessary for filling in surface

imperfections;

"High gloss coating" means a coating that, when tested by American Society for

Testing Material Test Method D523-08, Standard Test Method for Specular

Gloss, shows a reflectance of 85 or more on a 60 degree meter;

(o)

(P)

(Q)

"HVLP spray application’’ means to apply a coating using a coating application

system that uses lower air pressure and higher volume than conventional air

atomized spray systems, where the manufacturer has represented that the system

is HVLP by affixing a permanent label or through representations on the

packaging or other product literature;

"Overall control efficiency" means the product of the capture efficiency and the

control device efficiency;

"Pleasure craft" means any marine or freshwater vessel manufactured or operated

primarily for recreational purposes;

"Pleasure craft coating" means any marine coating, except unsaturated polyester

resin (fiberglass), applied to a pleasure craft or to parts and components of a

pleasure craft;
DRAFT

(s)

(T)

33

"Pretreatment wash primer" means a coating, containing at least 0. i percent acid

by weight and no more than 25 percent solids by weight, that is used to provide

surface etching and is applied directly to fiberglass and metal surfaces to provide

corrosion resistance and adhesion of subsequent coatings;

"Related cleaning" means the removal of uncured coatings, coating residue, and

contaminants from:

(u)

(i) pleasure craft or parts and components of pleasure craft prior to the

application of coatings;

(ii) pleasure craft or parts and components of pleasure craft between coating

applications; or

(iii) transfer lines, storage tanks, spray booths, and coating application

equipment; and

"Transfer efficiency" means the portion of coating solids that adheres to the

pleasure craft surface during the application process, expressed as a percentage of

the total volume of coating solids delivered by the applicator.

(2) Applicability.

(A) Except as provided in subdivision (3) of this subsection, the provisions of this

subsection apply to the owner or operator of any marina, boat yard, or other

premises where pleasure craft coating is applied for commercial purposes at the

direc*ion of such owner or operator, if:

(i) Such owner or operator was subject to subsection (s) of this section prior

to January 1, 2013, or

(ii) Such owner or operator purchases for use in all pleasure craft coating and

related cleaning at the premises 855 gallons or more of coatings and

cleaning solvents in aggregate per rolling 12-month period.

(B) An owner or operator subject to this subsection shall:

(i) For a source operating prior to January 1, 20!3, comply with the

requirements of this subsection no later than January 1,2013, or

(ii) For a source that connnences operation after January 1, 2013, comply with

the requirements of this subsection upon commencing operation.

(c) Any owner or operator subject to this subsection shall remain subject to this

subsection.

(3) Exemptions and exceptions.
DRAFT

(A) Except as provided in subdivision (7) of this subsection, the requirements of this

subsection shall not apply to any of the following activities, and the VOC

emissions resulting from the following activities shall not be included in

determinations pursuant to subdivision (2) or (4)(E) of this subsection:

(i) Coating and cleaning subject to one of the following subsections of this

section: (1) through (s) and (bh) through (jj),

(ii) Coating and associated surface preparation and cleanup subject to section

22a- 174-41 of the Regulations of Connecticut State Agencies,

(iii) Coating applied with a hand-held aerosol can,

(iv) Application of adhesive, sealant, adhesive primer or sealant primer

regulated by section 22a-174-44 of the Regulations of Connecticut State

Agencies,

(v) Coating applied to test materials, test panels and coupons in research and

development, quality control or performance testing,

(vi) Use of coatings containing VOC at concentrations less than 1.0 percent by

weight, or

(vii) Use of cleaning solvents containing VOC at concentrations less than 5.0

percent by weight.

(B) The requirements of subdivision (5) of this subsection shall not apply to the

application of an extreme high gloss coating.

(O An owner or operator may use in aggregate in any 12 consecutive months no

more than 55 gallons of pleasure craft coatings that exceed the VOC content

limits or emission limits of subdivision (4) of this subsection.

(4) On and after January 1, 2013, no owner or operator of a pleasure craft coating operation

shall apply any coating, inclusive of any VOC-containing material added to the original coating

supplied by the manufacturer, unless the owner or operator controls emissions of VOCs in

accordance with subparagraph (A), (B), (C), (D) or (E) of this subdivision. If more than one

emission limit or emission rate applies in a particular situation, then the least restrictive limit or

rote shall apply. An owner or operator shall:

(A) Use only coatings that have an as applied VOC content no greater than the

applicable level in Table 20(kk)-l.

(B) Use a combination of tow-VOC coatings and add-on air pollution control

equipment to achieve a VOC emission rate no greater than the applicable level in

Table 20(kk)-2.
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35

(c) Install, operate and maintain according to the manufacturer’s recommendations

air pollution control equipment with an overall control efficiency of at least 90%.

(D) Use an alternative means, achieving a level of control equivalent to subparagraph

(A), (B) or (C) of this subdivision, requested from and approved by the

commissioner in accordance with subsection (cc) of this section.

Limit the total potential VOC emissions from all pleasure craft coating operations

and related cleaning by permit or order of the commissioner to t,666 pounds or

less in any calendar month.

(5) Application methods. Except as provided in subdivision (3) of this subsection, an owner

or operator shall not apply a VOC-containing coating to a pleasure craft or to a part or

component of a pleasure craft unless the coating is applied by one of the methods identified in

subparagraphs (A) through (F) of this subdivision using equipment operated in accordance with

the specifications of the equipment manufacturer:

(A) Electrostatic application;

(B) HVLP spray application;

(C) Airless spray application;

(D) Air-assisted airless spray application;

(E) Hand application; or

Any other coating application method capable of achieving a transfer efficiency

equivalent to or better than that provided by HVLP spray application. Any

coating operation using an application method pursuant to this subparagraph shall

maintain records demonstrating, the transfer efficiency achieved.

(6) Work practices. Each owner or operator shall use the following work practices:

(A) New and used VOC-containing coating or cleaning solvent, including a coating

mixed on the premises, shall be stored in a nonabsorbent, non-leaking container.

Such a container shall be kept closed at all times except when the container is

being filled, emptied or is otherwise actively in use;

(B) Spills and leaks of VOC-containing coating or cleaning solvent shall be

minimized. Any leaked or spilled VOC-containing coating or cleaning solvent

shall be contained, absorbed and removed inamediately;

(c) Absorbent applicators, such as cloth and paper, which are moistened with a VOCcontaining coating or solvent, shall be stored in a closed, nonabsorbent, nonleaking container for disposal or recycling; and
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(D)

(7)

VOC-containing coating and cleaning solvent shall be conveyed from one

location to another in a closed container or pipe.

Records.

36

An owner or operator shall maintain records of information sufficient to

determine compliance with the applicable requirements of this subsection,

including, at a minimum, the information described in subparagraph (B) of this

subdivision. All such records shall be:

(B)

(i) Made available to the commissioner to inspect and copy upon request, and

(ii) Maintained for five years from the date such record is created.

An owner or operator shall maintain records of the following information for each

calendar month:

(c)

(i)

(ii)

(iii)

(iv)

(v)

(vi)

(vii)

Name and description of each coating and cleaning solvent,

VOC content of each coating and cleaning solvent, as applied, and the

associated calculations,

VOC content of each coating or cleaning solvent, as supplied,

The amount of each coating and cleaning solvent:

(I) Purchased, or

(II) Actually used,

A Material Safety Data Sheet, Enviromnental Data Sheet, Certified

Product Data Sheet, or an equivalent data sheet for each coating and

cleaning solvent,

Documentation of control device efficiency and capture efficiency, if

applicable, using an applicable EPA reference method or alternate method

as approved by the commissioner, and

Date and type of maintenance performed on air pollution control

equipment, if applicable.

Any owner or operator of any premises at which pleasure craft coating is

conducted who does not meet the applicability thresholds provided in subdivision

(2)(A) of this subsection shall maintain material purchase records to verify that

this subsection does not apply to such owner or operator.
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An owner or operator operating pursuant to an exception or exemption in

subdivision (3) of this subsection shall maintain records sufficient to verify the

applicability of the exception or exemption.

37

(8) Compliance procedures.

(A) The VOC content limits of Table 20(kk)-I apply to the volume of coating as

applied, determined using the following equation:

VOC Content = (Ws - Ww-Wes)/(Vm - Vw - Ves)

Where: ~’Vs = weight of volatile compounds in grams

Ww = weight of water in grams

Wes = weight of exempt compounds in grams

Vm = volume of coating in liters

Vw = volume of water in liters

Ves = volume of exempt compounds in liters

(B) The VOC emission rate limits of Table 20(kk)-2 apply to the mass of VOC

emitted per volume of coating solids, as applied.

(c) To determine the properties of a coating or components thereof in order to

perform the calculations required pursuant to subparagraph (A) of this subdivision

or to verify calculations based on the manufacturer’s formulation data, the VOC

and solids content of all coatings shall be determined using 40 CFR 60, Appendix

A, Reference Method 24 or an equivalent method, tn the case of a dispute, the

VOC content determined using Reference Method 24 shall contro!, unless a

person is able to demonstrate to the commissioner’s satisfaction that the

manufacturer’s formulation data are correct.

(D) Where a VOC content limit or emissions rate is provided in metric units and

equivalent English units, the limit or rate in metric units defines the standard. The

English units are provided for information only.

A pleasure craft coating shall be defined and categorized based on the

manufactm’er’s representations as set out on the container or label or in

information provided by the manufacturer of such a pleasure craft coating.
38

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Table 20(kk)-I

Pleasure Craft Coatin: VOC Content Limits

Extreme high gloss topcoat

High gloss topcoat

Pretreatment wash primer

Finish primer or surfacer

High build primer or surfacer

Aluminum substrate antifouling coating

Other substrate antifouling coating

Antifouling sealant or tie coat

All other pleasure craft surface coatings for

metal or plastic

g VOC/liter coating_

600

420

780

Effective until

December 31, 2015:

600

Effective January 1,

2016:420

340

560

4O0

420

420

lbs VOC/g.al coating_

5.0

3.5

6.5

Effective until

December 31, 20 t 5:

5.0

Effective January 1,

2016:3.5

2.8

4.7

3.3

3.5

3.5

Table 20(kk)-2

Pleasure Craft Surface Coatin VOC Emission Rate Limits

~ry

Extreme hig___h gloss topcoat

_High gloss topcoat

Pretreatment wash primer

Finish primer or surfacer

High build prime~ r or surfacer

Aluminum substrate antifouling coatin~g

Other substrate antifouling coating

Antifouling sealer or tie coat

All other pleasure craft surface coatings for

metal or~plastic

g VOClliter solids

1100

800

6670

Effective until

December 3 l, 2015:

1870

Effective January 1,

2016:800

550

1530

764

800

800

lbs VOC/gal solids

9.2

6.7

55.6

Effective until

December 31,

2015:15.59

Effective January

1, 2016:6.7

4.6

12.8

6.4

6.7

6.7

Statement of purpose: The main purpose of this proposal is to enhance existing and add ne~v

requirements to control volatile organic compound (VOC) emissions from two types of surface

coating operations. VOC emissions are a precursor to ground-level ozone, a harmful air

pollutant. The U.S. Environmental Protection Agency (EPA) is reconsidering the level of the

current national ambient air quality standards (NAAQS) for ozone and has initiated the

statutorily required review to be completed in 2013. All of Connecticut is expected to be in

nonattaiument of the reconsidered or revised ozone NAAQS. The proposed limitations on VOC

emissions will assist Connecticut to attain and maintain the federal ozone NAAQS.
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39

The Department of Energy and Enviromnental Protection (DEEP) cm’rently regulates VOC

emissions from metal parts coating under section 22a-174-20 of the Regulations of Comaecticut

State Agencies (RCSA). In response to EPA guidance, DEEP is proposing to add more stringent

VOC control requirements for metal parts and to broaden the applicability to include coating of

plastic parts. (Section 1)

Also in accord with EPA guidance, DEEP is proposing new requirements for addition to RCSA

section 22a-! 74-20 to limit VOC emissions from pleasure craft coating. Owners of marinas and

boat yards that coat pleasure craft will be required to meet the VOC content limits for coatings

and keep records of coatings and solvents purchased. (Section 5)

The requirements for both miscellaneous parts coating and pleasure craft coating include VOC

content limits for coatings applied; work practices that limit evaporation and waste of coatings

and solvents; coating application methods; and record keeping requirements.

Elements of the proposal aside from the parts and pleasure craft coaIing are minor revisions to

address the interaction of the revised and new requirements with other subsections of RCSA

section 22a-174-20. Such revisions are as follows:

Removing redundant record keeping requirements for owners and operators of

miscellaneous metal and plastic parts coating facilities (Section 2);

® Removing an artificial distinction between the use of permits and orders as the

enforceable mechanisms for alternative emissions control scenarios for sources of volatile

organic compound emissions (Section 3); and

Making a minor clarification to the industrial solvent cleaning requirements of subsection

(ii) of RCSA section 22a-174-20. (Section 4)

Attachment 3

Final Text of the Proposal, Based on Recommendations in the Hearing Officer’s Report

Section 1. Subsection (s) of section 22a-174-20 of the Regulations of Connecticut Sta~e

Agencies is amended to read as follows:

(s) Miscellaneous metal ~ parts [and products.] ~

[(1) For the purpose of this subsection:

"Air dried coating" means a coating that is dried by the use of air or forced warm air at

temperatures up to below 90 degrees C (194 degrees F).

"Clear coat" means a base or top coating which either lacks color and opacity or which is

transparent and uses the surface to which it is applied as a reflectant base or under~one color.

"Coating application system" means all operations and equipment that apply, convey and dry a

surface coating, including, but not limited to, spray booths, flow coaters, flashoff areas, air dryers

and ovens.

"Exposure to extreme environmental conditions" means exposure to: the weather all of the time;

temperatures consistently above 95 degrees C; detergents; abrasive and scouring agents;

solvents; corrosive atmospheres; or similar enviromnental conditions as determined by the

cmmmissioner and the Administrator.

"Extreme performance coatings" means coatings designed for exposure to exta’eme

enviro~amental conditions.

"Heat sensitive material" means materials that cmmot consistently be exposed to temperature

greater than 95 degrees C (203 degrees F) for more than 30 seconds.

"High performance architectural aluminum coating" means a coating that is applied to

architectural aluminum panels, extrusions or subsections to meet the specifications of publication

number AAMA 605.2-1992 of the Architectural Aluminum Manufacturer’s Association.

"Prime coat" means the first of two or more films of coating applied to a metal surface.

"Single coat" means one film of coating applied to a metal surface.

"Topcoat" means the final film or series of fitms of coating applied in a two-coat (or more)

operation.

"Transfer efficiency" means the portion of coating solids that adheres to the metal surface during

the application process, expressed as a percentage of the total volume of coating solids delivered

by the applicator.

(2) Applicability. For the purpose of this subsection:

(A) Miscellaneous metal parts and products includes the following industrial

categories:
2

(i)

(ii)

(iii)

(iv)

(v)

(vi)

(vii)

Large farm machinery such as harvesting, fertilizing and planting

machines, tractors, combines, etc.,

Small farm machinery such as lawn and garden tractors, lawn mowers,

rototiller, etc.,

Small appliances such as fans, mixers, blenders, crock pots, dehumidifiers,

vacuum cleaners, etc.,

Commercial machinery such as office equipment, computers and auxiliary

equipment, typewriters, calculators, vending machines, etc.,

Industrial machinery such as pumps, compressors, conveyor components,

thns, blowers, transformers, etc.,

Fabricated metal products such as metal covered doors, frames, etc., and

Any other industrial category which coats metal parts or products under

the Standard Industrial Classification Code of Major Group 33 (primary

metal industries), Major Group 34 (fabricated metal products), Major

Group 35 (nonelectric machinery), Major Group 36 (electrical machinery),

Major Group 37 (transportation equipment), Major Group 38

(miscellaneous instruments), Major Group 39 (miscellaneous

manufacturing industries), Major Group 40 (Railroad Transportation) and

Major Group 41 (Transit Passenger Transportation); and

(B) Miscellaneous metal parts and products excludes the following items:

(i) automobiles and light duty trucks,

(ii) metal cans,

(iii) flat metal sheets and strips in the form of rolls or coils,

(iv) plastic and glass objects,

(v) magnet wire for use in electrical machinery,

(vi) metal furniture,

(vii) the exterior surface of assembled aircraft,

(viii) automobile refinishing,

(ix) customized top coating of automobiles and trucks, if production is tess

than 5 vehicles per day, and

(x) the exterior surface of assembled marine vessels.
(3) Emission standards. No owner or operator of a facility engaged in the surface coating of

miscellaneous metal parts and products may operate a coating application system subject to this

subsection that emits volatile organic compounds from any coating in excess of:

(A) 0.52 kg/1 (4.3 lb/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator that applies a clear coat;

(B) 0.42 kg/1 (3.5 lb/gal) of coating, excluding water and exempt volatite organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator in a coating application system that is air dried or forced

warm air dried at temperatures up to 90 degrees C (194 degrees F);

(c) 0.42 kg/1 (3.5 ib/gal) of coating, excluding ~vater and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator that applies extreme performance coatings;

(D) 0.36 kg/l (3.0 Ib/gat) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as amended from time to time, delivered to

a coating applicator for all other coatings, adhesives, fillers or sealants and

coating application systems; and

(E) 0.75 kg/1 (6.3 Ib/gal) of coating, excluding water and exempt volatile organic

compounds listed in 40 CFR 51.100(s) as mnended from time to time, delivered to

a coating applicator which applies high performance architectural aluminum

coatings, provided that:

(i) such applicator is located at a premises which emits three thousand three

hundred thirty three (3,333) pounds of volatile organic compounds per

month or less from such applicator, and

(ii) such applicator was an existing source in Connecticut on or before

November 1, 1994.

(4) This subsection applies to all application areas, flashoff areas, air and forced air dryers

and ovens used in the surface coating operations pertaining to miscellaneous metal parts and

products listed in subsection (s)(2) of this section. This regulation also applies to prime coat, top

coat and single coat operations.

(5) If more than one emission limitation in subsection (s)(3) of this section applies to a

specific coating, then the least stringent emission limitation shall be applied.

(6) All volatile organic compound emissions from solvent washings shall be considered in

the emission limitations in subsection (s)(3) of this section unless the solvent is directed into

containers that prevent evaporation into the atmosphere.
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4

(7) The provisions of this subsection apply to any premises that has actual emissions of

volatile organic compounds of fifteen (15) pounds per day or more in any one day from all

miscellaneous metal parts and products surface coating operations on such premises unless:

(A) The total potential emissions from all surface coating operations are limited by

permit or order of the commissioner to 1,666 pounds or less in any calendar

month;

(B) The owner or operator is and has at all times been in compliance with such

limitation since the issuance of the permit or order;

(c) The total actual emissions from all such surface coating operations have not

exceeded 1,666 pounds in any calendar month since January 1987; and

(D) Notwithstanding subsections (A) through (C) of this subdivision, any surface

coating operation on such premises that emitted 40 pounds or more in any day and

that was subject to the requirements of this subsection prior to November 1, 1989,

shall remain subject to the provisions of this subsection.

(8) After November 1, 1989 any premises that is or becomes subject to the provisions of this

subsection shall remain subject to the provisions of this subsection unless the owner or operator

meets the requirements of subparagraphs (A), (B) and (C) of subdivision (7) of this subsection.

(9) . The owner or operator of an), surface coating operation that was not subject to the

requirements of this snhsection prior to November 1, 1989, shall have tmtil October 1, 1990, to

comply with the requirements of this subsection for such system.

(10) Notwithstanding the requirements of this subsection, an owner or operator may use, in

the aggregate, up to fifty-five (55) gallons of coatings that exceed the emission limitations set

forth in subdivision (3)(A) through (3)(E), inclusive, of this subsection at such premises for any

twelve (i 2) consecutive months, provided such owner or operator maintains records of such

coatings in accordance with subsection (aa) of this section. ]

Definitions. For the purposes of this section, the following definitions apply:

"Ablative coating" means a coating that chars when exposed to open flame or

extreme temperatures, as would occur during the failure of an engine casing2£

durin~ aerodynamic heating. The ablative char surface serves as an insulative

barrier, protecting_adjacent components from the heat or o.~

"Adhesion promoter" means a very thin coating applied to a substrate to promote

wetting and form a chemical bond with the subsequently applied material;

"Adhesive bonding primer" means a primer applied in a thin film to aerospace

components to inhibit corrosion and increase adhesive bond strength;

"Aerospace high temperature coating" means a coatin~ designed to withstand

temperatures of more than 350°F;
5

"AerosEace vehicle or component" means any fabricated pa_rt~rocessed part,

assembly of pa~ or completed unit, with the exception of electronic

~onents, of any aircraft including_but not limited to airplanes, helicopAm_~

missiles, rockets and space vehicles;

"Air dried" means cured at a temperature below 90°C ~

"Airless spray a~Eolication" means a coating spra_y~2plication ~stem usin~

fluid pressure, without compressed ~ to atomize the coatin2d

"Air-assisted airless spray ap_plicafion" means a coating spra2¢ aRplication system

using fluid pressure to atomize the coating and lower pressure air to a~id’ust the

shape of the spray ~

"Antichafe coating’_’ means a coatin a~p_plied to areas of movin~

components that may rub during normal operations or installation;

"Antique aerospace vehicle" means an aircraft or componant thereof that was

built at least 30 years ago. An "antique aerospace vehicle" would not routinely be

in commercial or military service in the capacity for which it was designed;

"ARpurtenance" means any accessory to a stationary structure, including.but not

limited to: bathroom and kitchen fixtures; cabinets; concrete forms; doors;

elevators; fences; hand railinj~s; heating equipment, air conditioning equipment,

and other fixed mechanical equipment or stationary_tools; lamppostskl_~artitions;

pipes and piping systems; rain gutters and downspouts; stairways; fixed ladders;

catwalks; fire escapes and window screens;

"As a_pAolied" means the composition of coating at the time it is a~tied to a

surface i,~5_ncluding any solvent, catalyst or other substance added to the coating but

excluding water and exempt con~

"Automotive-transportation part" memas an interior or exterior component of a

motor vehicle or mobile source;

"Baked" means cured at a temperature at or above 90°C (194°F);

"Bearing coatings" means a coating~pplied to an antifriction bearing~ a bearing

housinj~ or the area adjacent to such a bearing to facilitate bearing fmaction or to

protect base material fiom excessive wear. A material shall not be classified as a

~ coating" if it can also be classified as a dry lubricative material or a solid

film lubricant;

"Bonding maskant" means a temporary coating used to protect selected areas of

aerospace parts from strong acid or alkaline solutions during_processing for

bonding;
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6

"Business machine" means a device that uses electronic or mechanical methods to

process informatiun~perform calculations, print or cop_z.information or convert

sound into electrical impulses for transmission, such as, typewriters, electronic

computing devices, calculating and accounting machines~ telephone and tele raggAp~h

e~ku_ipment and photocopy machines_;

"Camouflage coating" means a coating used. princi allp~y~by the military,_to

conceal equipment from detection:

~ture efficiency" means the ratio of VOC emissions delivered to the control

device to the total VOC emissions resulting from the miscellaneous metal and

plastic parts coating operation, expressed as a percenta~

"Caulking and smoothing compound" means a semi-solid material that is applied

by hand and used to smooth exterior vehicle surfaces or fill cavities such as bolt

hole accesses. A material shall not be classified as a "caulking and smoothing

compound" if it can also be classified as a sealant;

"Chemical agent-resistant coating" means an exterior topcoat desigRed to

withstand exposure to chemical warfare agents or the decuntaminants used on

these ~

"Chemical milling maskant" means a coatin~ that is applied directly to aluminum

components to protect surface areas when chemically milling the component with

a Type I or II etchant. "Chemical milling maskants" do not include bonding

maskants, critical use and line sealer maskants, seal coat maskants, maskants that

are defined as specialty coatings or maskants used with either a Type I or II

etchant plus a bonding maskant, critical use and line sealer maskant or seal coat

maskant;

"Cleaning solvent" means any VOC-containing liquid, including a liquid_

impregnated wipe or towelette, used in cleaning:

"Clear coating~ means a colorless coating that contains binders but no pigment

and is formulated to form a transparent film;

"Coating" means a material that is deposited in a thin, persistent, uniform lay~

across the surface of a substrate for aesthetic, protective or functional upupupupupupupupup~oses.

Coatings include, but are not limited to, paints, primers, inks and maskants, but

exclude_protective oils, acids and bases;

"Coating unit" means a series of one or more coatin~ applicators and any

associated drying area or oven wherein a coatin~ is applied, dried or cured. A

"coating unit" ends at the point where the coating is dried or cured_, or prior to any

subsequent application of a different coating;

"Commercial exterior aerodynamic structure primer" means a primer used on

aerodynamic components and structures that protrude from the fuselage, such as
DRAFT

_w~ and attached corn o~ntrol surfaces, horizontal stabilizers, vertical

_fins_, wing-to-body fairings, antennae and landin~ear and doors for the_~

of extended corrosion ~protection and enhanced adhesion’

B.(_B_B_) "Colm:aercial interior adhesive" means a material used in the bonding O_Q_f

~er cabin interior com~

°’Compatible substrate primer" means one of the following c~

~_primer that is compatible with the titled elastomeric coating and is

based

~primer that inhibits corrosion and is applied to bare metal surfaces or is

_a~rior to adhesive a_RplicatioN or

A primer that is applied to surf5ces that can be expected to come into

contact with fuel, with the exception of coatings~applied to fuel tanks;

"Control device efficiency~ means the ratio of VOC emissions recovered or

~¥ the contro! device to the total VOC emissions that are introduced

into the devic~e e~_pressed as a ~

~°Corrosion prevention compound" means a coating system that provides

corrosion protection by displacing v~ater and penetrating substrates, forming_a

l~rotective barrier between the metal surface and moisture. A coatinj~ containin~

oils or waxes is excluded from this cater5

"Critical use and line sealer maskant" means a temporary coating, not covered

under other maskant categories, used to protect selected areas of aeros~

from strong acid or alkaline solutions such as those used in anodizing, platin_g~

chemical milling and processin ofma nesium titanium or high A8 stren tggh_h

~recision aluminum chemical milling of deep cuts and aluminum

chemical millin of complex shapes. Materials used for re_pairs or to bridg~ ag&I~

left b~erations are also included in this cate ogp2y;

~emc flexible primer" means a rimer desi ned to- rovide corrosion

resistance, flexibility and adlaesion of subsequent coatinN systems when exposed

to loads up to and surpass~N the yield point of the substrate at cryogenic

temperatures (-275°F and below);

~protective coating" means a coating that insulates crvoaenic or subcooled

surfaces to limit propellant boi!-off, maintain structural integrity of metallic

structures during ascent or re-entr ay_k~d_prevent ice formationi

"Cyanoacr¥1ate adhesive" means a fast-settin~Nle component adhesive that

cures at room temperature mad co~i, ethyl, methoxymethy1 or other

functional rou’m s ofc anoacr late"

~n~" means a method of aRR!yj_nN a coating.to a surface bY submersion

into and removal from a coating bathl
8

DRAFT

"Drum" means any cylindrical metal container larger than 12 gallons capacity and

less than or equal to 110 gallons capacitg2

~ lubricative material" means a coating consisting of lauric acid, cetyl alcohol

waxes or other non-cross linked or resin-bound materials that act as a dry

lubricant;

"Electric dissipating coating" means a coating that rapidly dissipates a hig~hvoltage electric charge;

"Electric-insulating and thermal-conducting coating" means a coating that

displays an electrical insulation of at least 1000 volts DC per mil on a flat test

l~late and an average thermal conductiviW of at least 0.27 BTU per hour-footdegree-Fahrenheit;

"Electric-insulating varnish" means a coatinggpplied to electric motors,

components of electric motors or power transformers to provide electrical,

mechanical and environmental protection or resistance;

"Electric or radiation-effect coating" means a coating or coating system

e__ngineered to interact, through absorption or reflection, with specific regions of

the electromagnetic energy spectrum, such as the ultraviolet, visible~ infrared or

microwave regions. Uses include, but are not limited to, lightnin~

protection, electromagnetic pulse (EMP) protection and radar avoidance

"Electrostatic application" means a method of applying_coating particles or

coating droplets to a grounded surface by electrically charging such particles or

"Electrostatic discharge and electromagnetic interference coating" or "EMI

coating" means a co.ating applied to space vehicles, missiles, aircraft radomes and

helicopter blades to disl?erse static energy or reduce electromagnetic interference;

"Electrostatic t~paration coating" means a coating_applied to a plastic part solely

to provide conductivity for the subsequent application of a primer, a topcoat or

other coating through the use of electrostatic apl~lieation methods;

"Elevated-temperature Skydrol-resistant commercial primer" means a primer

~rimarily to commercial aircraft or corrmaercial aircraft adapted for

military use that must withstand immersion in phosphate-ester hydraulic fluid

(Skydrol 500b or equivalent) at the elevated temperature of 150°F for 1 0,~9_00

hours;

"EMI/RFI shield coating" means a coating that functions to attenuate

electromagnetic interference, radio frequency interference signals or static

dischar_g~
DRAFT

9

" ]!~p~amlde op o ~ " t c at" means a coating containinK_e.~E~ljtamide

col~ponent used to provide a hard., durable, chemical-resistant finish;

"Etching filler" means a coating_that contains less than 23% solids by weivht and

at least 0.5% acid by weight and is used as a substitute for the application of a

pretreatment coating followed by a~

"Exempt cor!!round" means a carbon compound excluded from the definition of

"volatile organic compound" as defined in section 22a-174-1 of the Regulations

of Com~ecticut State Algencies"

"Extreme high-~oss coating" means a coating that~ when tested by American

Society for Testing Material Test Method D523-08,. Standard Test Method for

_Specular Gloss, shows a reflectance of 75 or more on a 60 degree meter;

"Extreme performance coating" means a coatinN used on a metal surface where

the coated surface is, _ija its intended u~ su~bect to one of the following

conditions:

Chronic exposure to corrosive~_caustic or acidic agents,_chemicals

chemical fumes~ chemical mixtures or solution,

_Re_~eated exposure to temperatures in excess of 250°F, or_

KeLoeated heavy abrasion, including mechanical wear and repeated

scrubbing with industrial grade solvents, cleaners or scour~

"Fire-resistant interior coating" means, for civilian aircraft,, fire-resistant interior

coatings used on pas~er cabin interior parts that are subject to Federal

Aviation Administration fireworthiness requirements. For military aircraft~ fireresistant interior coatings are used on parts that are subiect to the flammability

re__qujrements of MIL-STD-1630A and MIL-A-87721. For spac~plications~

"fire-resistant interior coatin.g~’ means a coatin sg,_~_@j_b’ect to the flammabilit~z

requirements of SE-R-0006 and SSP 30233;

"Flexible primer" means a primer with elastomeric qualities that provides a

compatible, flexible substrate over bonded sheet rubber and rubber-ty!~

coatingK,

~ht test coating" means a coating applied to aircraft other than missiles or

s_~gle-use aircraft prior to flight testing to protect the aircraft from co~Tosion and

~rovide ~~ durin~ flight test evaluation;

Flow coating means a non-atomized techm~ coating to a

substrate using a fluid nozzle in a fan pattern with no air supplied to the nozzle;

~coat" means a coating that is_a~plied to g~plastic part at a thicl~aess of no

more than 0.5 mils of coatinKsolids for the p3~ose of color matching_without

maskin~ a molded-in texture;
10

DRAFT

"Fuel tank adhesive" means an adhesive that must be compatible with fuel tank

coatings and is used to bond components exposed to fuel;

"Fuel tank coating" means a coating applied to fuel tank components for the

purpose of corrosion or bacterial growth inhibition and to assure sealant

adhesion in extreme environmental conditions;

"General aviation rework facility" means any aerospace facility with the

~¥ of its revenues resulting from the reconstruction, repair, maintenance,

repainting, conversion or alteration of general aviation aerost~ace vehicles or

components;

"Gloss reducer’’ means a coating that is applied to a_plastic part at a thickness of

no more than 0.5 mils of coating solids solely to reduce the shine of the part;

"Heat-resistant coating" means a coating able to withstand a temperature of at

least 400° F during_normal use;

2_’_’_’_’_’_’_’_’_’~gh-performance architectural coating" means a coating used to23rotect

architectural subsections and which meets the requirements of the Architectural

Aluminum Manufacturer Association’s publication number AAMA 2604-0~

(Voluntary_Specification, Performance Requirements and Test Procedures for

High Performance Organic Coatings on Aluminum Extrusions and Panels) or

2605-05 (Voluntary Specification, Performance Requirements and Test

Procedures for Superior Performing Organic Coatings on Aluminum Extrusions

and Panels);

~ temperature coating_" means a coating certified to withstand a

temperature of 1000°F for 24 hours;

"HVLP spray_ application" means to apply a coating_using a coatin~ application

system that uses lower air pressure and higher volume than conventional air

atomized spray systems, where the manufacturer has represented that the system

is HVLP b~ermanent label or through representations on the

acRg.9.ka_gka ing or other product literature2

"Insulation covering" means material that is applied to foam insulation to

I)rotect the insulation from mechanical or environmental damage;

"Intemaediate release coating" means a thin coating applied beneath topcoats to

assist in removing the topcoat in depaintin~erations and to allow the use of

less hazardous depaintin~ methods;

"Lacquer" means a clear or pigmented coating formulated with a nitrocellulose

or synthetic resin to dry by evaporation without a chemical reaction. "Lacquers"

are resolnhle in their original solven£
DRAFT

LQ_O_Q 2~:~e commercial aircraft" means an aircraft of more t_han 1 !0 000_p~._un~ds

maximum certified take-off weight, 1_nanufactured for non-militmiyAks_e_;

tl

"Mask coating" means thin film coating a~2plied throug_~39_~_plate to coat a

small portion of a substrate;

SL~S~) "Medical device" means an instrument, a~2R~at___us, implement~ machine._ga~g~

~ implant, in vitro reagent or other similar or related art_Me, including

any componant~part or accessory, ~vhich meets one of the followinKconditions:

Recognized in the official National Formularx or the United States

Pharmacopeia or any supplement thereto,

Intended for use in the diaNnosis of disease or other conditions or in the

cure, mitigation treatment or prevention of disease in_~?ersons or

animals or

Intended to affect the structure or function of the body 9~g~Derson or

animal and which does not achieve its ~ intended purposes

through chemical action within or on such body and which is not

~pendent upon being metabolized for the achievement of its ~

intended purposes;

"Metalized e~eans a coating that contains relatively~g~

fluantities of metallic ~p~gmentation for aRp~arance or added protectionl

"Metallic coating" means a coating_that contains more than five grams of metal

particles per liter of coating, as applied;

"Miscellaneous metal and plastic.parts" means metal and plastic components of

products as well as the products themselves constructed either entirely_ or

partially from metal or plastic including, but not limited to: aerospace vehicles

and components, fabricated metal products~ molded plastic parts, small and

k~ge farm machinery, commercial and industrial machine~~~

automotive or trans~Dortation e ui rnent interior or exterior automotive parts,

construction equipment, motor vehicle ac~cles and ~porting

tours recreational vehicles~ extruded aluminum structural com~ railroad

ca_g~rs l~af_den equipment, business mach__ines, laborator_v and medical

e~uipment, electronic e ui merit steel drumg~s and small a liances

"Mold-seal coating" means the initial coating applied to a new mold or a

repaired mold to provide a smooth surface that, when coated with a mold

release coating_prevents products from stickinjz to the mold;

~X~ "Mold release" means a coatinxAt2plied to a mold surface ~revent the molded

y_~iece from sticking to the mold as it is removed;
DRAFT

12

"Motor vehicle" means any_self-propelled vehicle, including, but not limited to,

cars trucks, buses, golf carts, vans, motorcycles, tanks and armored personnel

carriers;

"Motor vehicle bedliner coati_ng" means a multi-component coating applied to a

cargo bed after the application of a topcoat to_provide additional durability and

chip resistance;

"Motor vehicle cavity wax" means a coatin ag~Rplied into the cavities of the

vehicle primaril_y for the purpose of enhancing corrosion protection;

BB~B~2~B~ "Motor vehicle deadener" means a coating applied to selected vehicle surfaces

~ for the purpose of reducing the sound of road noise in the passenger

compartment;

"Motor vehicle gasket/sealing material" means a fluid applied to coat a gasket

or.q_.~r~lace and perform the same function as a gasket. Automobile and lightduty truck gasket/Ka_sket sealing material includes room temperature

vulcanizatio.n (RTV) seal material;

DD(~_D_D_~ "Motor vehicle lubricating wax/compound" means a~protective lubricatihg

material applied to vehicle hubs and bin eg~;

"Motor vehicle sealer" means a high Viscosity material generally, but not

always, applied in the paint shop after the body has received an

electrode_p~sition primer coating and before the application of subsequent

coatings (e.g., primer-surfacer). The primary_purpose of automobile and lig~-

duty truck sealer is to fill body j.oints completely so that there is no intrusion of

wat_kDx~ases or corrosive materials into the passenger area of the body

compartment. Such materials are also referred to as sealant, sealant ~

"Motor vehicle trunk interior coating’ means a coating applied to the trunk

interior to provide chip protection;

(GGGG) "Motor vehicle underbody coating" means a coating applied to the

undercarriage or firewall to prevent corrosion or provide chip protection;

!"HHHH) "Multi-colored coating" means a coating packaged in a single container and

applied in a single coat which exhibits more than one color when applied;

"Multi-component coating" means a coating requiring the addition of a se_l~arate

reactive resin, such as a catalyst or hardener, before application to form an

acceptable dr~

"Nonstructural adhesive" means an adhesive that bonds nonload bearing

aerospace components in noncritical applications and is not covered in an21 other

specialty adhesive categories;
DRAFT

13

K~E~_K_~ "One-component coatingS’ means a coating_that is rea___dy for application as

t!ackaged for sal~t for the addition of a thinner to reduce the viscosityi

"Optical antireflection coating" means a coating with a low reflectance in the

infrared and visible wavelen It ~ ran es that is used for antireflection on or

near oI?tical and laser hardware;

~MMMM) "Optical coating" means a coating with a low reflectance in the infrared and

visible wavel~ that is used on or near o_~tical or laser lenses or

hardware;

"Overall control efficiency’_’ means the product of the capture efi~cienc~

the control device efflciency~

"Pan-backing coating’_’ means a coatin ag_a.Rp!lied to the surface of ~ans or

other cooking implements that are exposed directly to a flame or other heating

element;

°_’Part marking coating" means coatings or inks used to make identif¥i~

markings on materials, components or assemblies. These markings may be

either pelrnanent or tera~

~’Plastic part" means any piece or combination of pieces of which at least one

has been formed from one or more resins. Such pieces may be Solid, ~

flexible or rigid. "Plastic parts" do not include.parts made of fiberglass or

coml?osite materialsl

°~Prefabricated architectural coml~onent coatingS’ means a coating applied to

prefabricated metal2oarts and products that are to be used as architectural

_appurtenances or structures and that are detached from the structure when

coated in a shop environment;

~Pretreatment coating" means a coatin~ at least 0.5 percent acid

b_y weight, applied directly to a metal or composite surface to provide surface

etchin.K~ corrosion resistance, adhesion and ease of stripping;

T(~_TT) "Primer" means a coating applied to prevent corrosion, provide protection or

provide a surface for adhesion of subsequent coatin~

"Radome" means the nonmetallic protective housing for electromag_netic

transmitters and receivers such as radar or electronic countermeasures;

~VVV_~yJ "Rain erosion-resis}ant coating2 means a coating or coating s_ystem used to

protect the leading ed~uch as flaps, stabilizers, radomes or eng~K¢

inlet nacelles against erosion caused by ra~~

(WWWW)~Related cleaning’_’ means the removal of uncured coatings~residue

and contaminants from:
14

DRAFT

Miscellaneous metal and plastic parts prior to the application of

coating~

i~) Miscellaneous metal and plastic parts between coatin~ applications, or

Transfer lines, storage tanks, spray_ booths and coatin~ application

"Repair coating" means a coating used to recoat portions of a product that

has sustained mechanical damage to the coating following normal paintin~

operations;

"Resin" means an5, of numerous physically similar polymerized synthetics

or chemically modified natural materials including thermoplastic materials "

such as polyvinyl~ polystyrene and polyethylene and thermosetting_materials

such as ~, epoxies and silicones;

"Resist coating" means a coating that is applied to a plastic part before

metallic ~prevent deposits of metal on portions of the plastic, a.p24~

£AAAAA) "Rocket motor nozzle coating" means a catalyzed epoxy coating system

used in elevated temperature applications on rocket motor nozzles;

(BBBBB) "Roll coating" means a coating method using a machine that applies coating

to a substrate b_¥ continuously transferring coatin~ through a set of

o ositel rotatin rollers"

(CCCCC) "Rubber-based adhesive" means a quick-setting contact cement that

provides a strong, yet flexible bond between two substrates that may be of

dissimilar materials;

~_DDDDD& "Safety-indicating coatingS’ means a coatinKthat changes in a physical

characteristic, such as color, to indicate unsafe conditions;

"Scale inhibitor" means a coating_that is a_!2plied to the surface of a part

prior to thermal processin~ to inhibit scale formation;

"Screen print ink" means an ink used in screen printin~ processes during

fabrication of decorative laminates and decals;

(GGGGQ) "Sealant" means a material used to prevent the intrusion of water, fuel, air or

other liquids or solids from certain areas of aerosl~ace vehicles or

components;

£HHHHH) "Seal coat maskant" means an overcoat applied over a maskant to improve

abrasion and chemical resistance during production operations;

"Self-priming topcoat" means a topcoat that is applied directly to an

uncoated aerospace vehicle or component for corrosion prevention,
DRAFT

15

environmental protection or functional fluid resistance. More than one layer

of identical coatin~ formulation may be aRplied to the vehicle or cotn~

"Shock-free coating" means a coating aRplied to electrical components to

protect the user from electric shock. The coating provides for low

c_a~pacitance and h~g.h resistance and resists breaking down under highh

£KKKKK) °°Silicone insulation material" means an insulating material al~lied to

exterior metal surfaces for protection from high_temperatures caused by

atmospheric friction or engine exhaust. °°Silicone insulation materials"

differ from ablative coatings in that "silicone insulation materials" are not

sacrificial;

"Silicone-release coating" means any coating that contains silicone resin and

is intended to prevent food from sticking to metal surfaces such as baking

,(~_MMMM)"Solar-absorbent coating" means a coating.that has as its primary pUXRQ~

the absorption of solar radiation;

"Solid-film lubricant" means a very thin coating consisting~ of a binder

szvstem containing as its chief pigment material one or more of molybdenum

disulfide~_Rg_lytetrafluoroethylene or other solids that act as a drg

lubricant between laying surfaces;

£ooooo) "Space vehicle" means a man-made device~ either manned or unmanned~

designed for operation beyond earth’s atmosphere. This definition includes

.integral equipment such as models, mock-ups, prototype_s, molds, jigs,

toolin~ackets and test coupons. "Space vehicle" includes

auxili eary~qg~ment associated with test, transport and storage, which

through contamination can corn_promise the space vehicle performance;

"Specialty coating" means a coating that, even though it meets the definition

of a primer, topcoat or self-priming topcoat, has additiona! performance

criteria beyond those ofp_rimers, topcoats mad self-priming topcoats for

specific applications. These performance criteria may inch;de, but are not

limited to, temperature or fire resistance, substrate compatibility,

gntireflection, temporary protection or marking, sealing, adhesion or

enhanced corrosion l~rotection;

"Specialized function coating" means a coating_that fulfills extremely

specific engineering requirements. A "specialized function coating" is

limited in application, characterized _by !ow volume usage and is not able to

be categorized as any other coating in Table 20(s)-6a;
DRAFT

16

(RRRRR) ~’Stencil coating" means an ink or a coating that is rolled or brushed onto a

template or stamp to add identi ify~g letters or numbers to metal parts or

products;

"Structural autoclavable adhesive" means an adhesive used to bond loadcarrying aerospace components that is cured by heat and pressure in an

autoclave;

"Structural nonautoclavable adhesive" means an adhesive cured under

ambient conditions that is used to bond load-carrying aerospace components

or other critical functions, such as nonstructural bonding in the proximity of

~uuuuu) "Temgg_r~rotective coating" means a coatingApplied to provide scratc_h

or corrosion protection during manufacturing, storage or transportation.

"Temporary protective coatings" do not include coati~rotect a~gainst

strong acid or alkaline solutions;

(VVVVV_) "Texture coat" means a coating that is al~plied to a plastic part which, in its

finished form, consists of discrete raised spots of the coating;

(WWWWW) "Textured finish" means a rough surface produced by spraying and

splattering large drops of coating onto a previously applied coating

£XXXXX) "Thermal control coating" means a coating formulated with specific thermal

conductive or radiative pro~gerties to permit temperature control of the

substrate;

(YYYYY) "Touch-up coating" means a coating used to cover minor coating

imperfections appearing after the main coating operation;

"Transfer efficiency" means the portion of coating solids that adheres to the

metal or plastic surface during the application process, expressed as a

percentage of the total volume of coating solids delivered by the_ ~

£AAAAAA)"Translucent coating" means a coating which contains binders and pigment

and is formulated to form a colored, but not opaque, film;

~BBBBBB~ "Vacuum-metal;zing coating" means the undercoat applied to a substrate on

which the metal is deposited prior to a vacuum-metalizingA?rocess or the

overcoat mAp.plied directlld to the metal film after a vacuum-metal;zing

!’CCCCCQ) "Vacuum metalizing process" means the.process of eva~

metals inside a vacuum chamber and depositin~g them on a substrate

to achieve a uniform metalized la eye;
DRAFT

(DDDDDD~ "Wet t~astener installation coating" means a primer or sealant applied by

~3g~ br~ or daubin~ to_ fasteners that are installed before the

coatin~ is cured" a,~Kd_nd

~EEEEEE) ~" means a corrosion-resistant topcoat that withstands the

flexing_of aircraft wings and rotar~

17

&p_plicabilitL.

_(&) Except as provided in subdivision (7) of this _subsection~ the provisions of this

subsection apply to the owner or operator of any miscellaneous metal and_plastic

l?arts coating unit:

~) That is subject to this subsection prior to January 1, 2013, or

For which the owner or opera_tor purchases for use at the premises 855

gallons or more of coatings and cleaning solvents in a~r_e_~ rolling

12-month period.

LB_)_ An owner or operator subiect to this subsection shall:

i~_ For an existing miscellaneous rnetat and plastic parts coating uait, comply

with the requirements of this subsection no later than January 1, 2013~ or

For a miscellaneous metal mad plastic parts coatin~ unit that commences

operation after January 1, 2013~ com_pj.ly with the requirements of this

subsection upon commencing operation.

Any owner or operator subject to this subsection shall remain subject to this

subsection.

3~) Except as provided in subdivision (7) of this subsection, on and after Janum’y !, 2013, no

owner or operator shall ap_ply any coating, inclusive of any VOC-containin~ material added to

the:original c0atin~ supplied b2g the manufacturer, unless the owner or operator controls

emissions of VOCs in accordance with sub~) or (D) of this subdivision. If

more than one emission limit or emission rate applies in a particular situation, then the least

restrictive limit or emission rate shall a~p_ly. An owner or o~?erator shall control the emission of

VOCs as follows:

Use only coatings that have an as a_Rplied VOC content no greater than the

a~2t?licable level in Table 20(s)-l, 20(s)-2~20(s)-3, 20(s)-4, 20(s_~-5~ 20(s)-6a or

20@ 

For a coating unit, use a combination of low-VOC coatings and add-on air

pollution control e~ment to achieve a VOC emission rate no t~reater than the

adkp_licable level in Table 20 s(~)-7, 20(s)-8, 20(s)-9, or
DRAFT

18

Install operate and maintain according to the manufacturer’s recommendations

air pollution control equipment ~vith an o-4erall control efficiency of at least 90%;

An alternative means, achieving a level of control equivalent to subpara ra hg~

~B_) or (C) of this subdivisi~uested from and approved by the commissioner

in accordance with subsection (cc) of this section.

~) A_Rplication methods. Except as provided in subdivision (7) of this subsection, an owner

~erator shall not a!~l a VOC-contaiuing coating to a miscellaneous metal and plastic par~_

unless the coating is applied by one of the methods identified in subparagraphs (A)_through (I) of

this subdivision usin~ equipment operated in accordance with the specifications of the equipment

manufacturer:

Electrostatic application;

Flow coating:

Roll coating;

HVLP spray application;

Airless spray application;

Air-assisted airless spray application;

Hand application; or

Any other coating application method capable of achieving a transfer efficiency

equivalent to or better than that provided by HVLP spray apI~lication. Any owner

or ol?erator using an application method pursuant to this subparagraph shall

maintain records demonstrating the transfer efficiency achieved.

Work practices. Each owner or operator shall use the followin~ work practices:

New and used VOC-containing_coating, diluent or cleaning solvent, including a

coating mixed on the premises, shall be stored in a nonabsorbent, non-leaking

container. Such a container shall be kept closed at all times except when the

container is bein~ filled, emptied or is otherwise actively in use;

Spills and leaks of VOC-containinKcoatin~, diluent or cleaning solvent shall be

minimized. Any leaked or spilled VOC-containing coating, diluent or cleaning

solvent shall be absorbed and removed immediately;
19

Absorbent applicators, such as cloth and paper~ which are moistened with a VOC-

~~ or solvent, shall be stored in a closed, nonabsorbent,, nonleaking_container for disposal~ and

VOC-containing coatings, diluent and cleanin2~ solvent shall be conveyed from one

location to another in a closed container or pipe.

~) Notwithstanding the requirements of this subsection, an owner or operator comR!yj~

with this subsection by~perating under a valid pe~rnit or order issued pursuant to subsection

~_)_(_2_)_ or (cc)(3) of this section shall continue to operate according_to the tenThS of such permit or

order.

Exemptions and exce20tions.

Except as provided in subdivision (8) of this subsection, the requirements of this

subsection shall not apply to any of the following activities, and the VOC

emissions resulting_from the following activities shall not be included in

determinations pursuant to subdivision_C~) or (7)(0) of this subsection:

Coating and cleaning su~jb’ect to one of the following subsections of this

~ through (r) and (hh)~

Coatin ’ aKARplied in an automotive refinishing operation and related

cleanin~

Coating and associated surface preparation and cleanup subject to section

22a-174-41 of the Regulations of Connecticut State A~

Coating a_Rplied to test materials, test panels and coupons in research and

develo me~_~Kak_qualitv control olzI?erfonnance testing~

Coating~lied in a ship_building and repair operation, provided that the

operation is subject to 40 CFR 63 Sub ~R_~_~II

Coating~t?_plied to space vehicles and related cleanin2~

Coating a_p~lied to antiqKe_ aerospace vehicles and related cleaning,

Coating applied with a hand-held aerosol can~

Adhesive, sealant, adhesive primer or sealant primer regulated by section

22a-174-44 of the Regulations of Connecticut State Agencies

~9. ~ntrol or inspection ~lied to metal p~

xf~ Use of coatings containin~ VOC at concentrations less than 1.0 percent by
DRAFT

2O

x~j~) Use of cleaning solvents containingVOC at concentrations less than 5.0

percent by weig~L

~ Maintenance coating and related cleaning of fixtures, equipment and

components that are not products manufactured by the facility or products

coated on a contract basis.

The requirements of subdivisions (3) and (4) of this subsection shall not a&pJzL0_

the application of any of the following coatings to metal parts:

Stencil coating~

Safety-indicating coating~

Solid-film lubricant,

Electric-insulating and thermal-conductin~ coating,

~gg~netic data storage disk coating~

Plastic extruded onto metal parts to form a coating~9£

Powder coating.

The requirements of subdivision (3) of this subsection shall not a~

application of any of the fol!owing coatings to plastic parts:

Touch-up and repair coating,

Stencil coatin~ applied on a clear or transparent substrate,

Clear or translucent coating,

Reflective coating applied to a highway cone,

Mask coating less than 0.5 millimeter thick applied to an area less than 25

square inches,

EMI/RFI shield coating,

v(y~) Any heparin-benzalkonium chloride (H_BAC)-containing coatin~

to a medical device, provided that the total of all HBAC-containing

coatings used at a facility does not exceed 100 ~allons per year, o_r

~ Powder coating:.
DRAFT

21

The requirements of subdivision (3) of this subsection shall not ~ to the

~aj~plication of any_ of the following~ to automotive-transportation and

business machine 9arts:

Vacu_um ~ e~ talizin coatin

Gloss reducer~

Texture coat,

~Adhesion~

Electrostatic ~preparation coating~

Resist coating~

Stencil coating,_~

Powder coating.

The requirements of subdivisions (3) and (4) of this subsection shall not a.RpJ2~0~

_the application of any of the followin~ specialty coatings_ to an aerospace vehicle

or corn_portent:

2) Touch-up coating, or

Aerospace coating_that the United States Department of Defense has

des~ated as classified information in accordance with 32 CFR 2001.

The requirements of subdivision (4) of this subsection shall not apply to the

followin~ activities:

312_plication of touch-up and repair coating to metal parts,

Application of textured finish to metal part~

_Application of powder coatin_ tg~."

~ Plastic ap.k~

I~) Automotive-tran~portation~jlastic parts, o_r

~ Business machine ~

Airbrush aRplication of coating to metal or plastic p~arts using_no more

~than five ~allons of coatin~ per y~
DRAFT

22

Use of air pollution control equipment to comply with subdivision

this subsection~_o_r

_Application of sRecialt¥ coatings listed in Table 20~-6a of this

subsection.

An owner or operator with total potential VOC emissions fiom all miscellaneous

metal and plastic parts coating_including emissions from related cleaning, limited

b_y permit or order of the commissioner to 1,666 pounds or less in any calendar

month~ shall not be subject to the requirements of subdivision (3) of this

subsection, provided that the owner or operator operates in compliance with such

_a permit or an order.

An owner or operator may use in aggregate in any 12 consecutive months no

more than 55 gallons of miscellaneous metal or plastic parts coating or coatings

that exceed the VOC content limits or emission limits of subdivision 3~ of this

subsection provided the owner or operator maintains records of non-compliant

coating use.

Im An owner or operator controlling emissions as provided in subdivision (3) of this

subsection is exempt from any obligation to comply with subsection (bb) of this

section.

The requirements of subdivision (3) of this subsection shall not appl u.x,_gR~

request to and approval by the commissioner and the Administrator. Any reKu~

for approval shall be made in writing to the commissioner and shall include a

description of the noncompliant coating and its VOC content, an explanation of

why the noncompliant coating is necessary, the aggregate amount in gallons or

pounds of noncompliant coating use anticipated in a 12-month period and the

frequency of use of the noncompliant coatin~

Records.

Except as provided in subparag£aphs (B) and (Q), an owner or operator shall

maintain records of information sufficient to determine compliance with the~

applicable requirements of this subsection, including, at a minimum, the

following information for each calendar month:

Name and description of each coating and cleaning solvent,

VOC content of each coating and diluent, as applied, and the associated

calculations,

VOC content of each coating or cleaning solvent,

The amount of each coating and cleaning solvent:

Purchased,
DRAFT

23

A Materia! Safety Data Sheet, Enviromaaental Data Sheet~_Certified

Product Data Sheet~ or an efl~aivalent data sheet for each coatin.g_and

cleaning solvent,

!"vi) Documentation of control device efficiency an__d capture efficiency; if

a_p_plicable, using_an_Kkp~licable EPA reference method or alternate method

as a!?prove~t by the commissioner mad the Administrator, a~nd

Date and type of maintenance performed on air2oollution control

e~ment, if applicable.

_A_n.y owner or operator who does not meet the applicability thresholds provided in

subdivision (2)(A) of this subsection shall maintain either material purchase or

actual usage records to verify that this subsection does not aRp~ly to such owner or

_operator.

An owner or operator operatin~g@ursuant to an exception or exemption in

subdivision (7) of this subsection shall maintain records sufficient to verif tB4~he

a_Eplicability of the exce.~tion or exemption.

All records made pursuant to this subdivision shall be:

Made available to the commissioner to inspect and co--on request, and

Maintained for five years from the date such record is created.

Compliance procedures.

The VOC content limits of Table 20(~)-1, 20(s)-2, 20(_s)-3, 20(s)-4, 20(s)z~ 20 s(~:

~)-6b apply to the volume of coatin~etermined usin~ the

following equation:

VOC Content = (Ws - Ww-Wes~n - Vw - Ves)_

Where: Ws = weight of volatile compounds in_~grams

Ww = weight of water in grams

Wes = weight of exempt compounds .~ggams

Vm = volume of coating in liters

Vw = volume of water in liters

Ves = volume of exem~oands in liters

The VOC emission rate limits of Table 20(s)-7, 20(s)-8, 20(s)-9, or 20(s_)- 10 a~t2pjy_

to the mass of VOC emitted per volume of coatin~~lied.
DRAFT

24

To determine the properties of a coating or components thereof in order to

perform the calculations re uqg~_ed pursuant to sub.p_aragraph (A) of this subdivision

or to verify calculations based on the manufacturer’s formulation data. the VOC

and solids content of all coatings shall be determined using 40 CFR 60, Appendix

~ference Method 24 or an equivalent method. In the case ofa dis~

VOC content determined using Reference Method 24 shall control, unless a

person is able to demonstrate to the satisfaction of the commissioner and the

Administrator that the manufacturer’s fo~nulation data are correct.

For red,yellow or black automotive coatings, except touch-up and repair coatings,

the applicable VOC cuntent limit or emission rate shalt be the limit of Table

20(s)-3 or 20£~)-9, as applicable, multiplied by 1.15.

Where a VOC content limit or emissions rate is provided in metric units and

equivalent English units, the limit or rate in metric units defines the standard. The

.~dish units are provided for information onl~

A miscellaneous metal or plastic parts coating shall be defined and categorized

based on the manufacturer’s representations as set out on the cuntainer or label or

in information provided by the manufacturer of such a miscellaneous metal or

plastic parts coating.

Limitations on potential to emit.

An owner or operator may submit a request to the commissioner for an order or

permit to limit potential emissions from all miscellaneous metal and plastic parts

coating at the premises to a monthly limit of 1,666 pounds of VOC; or

An owner or operator issued a permit or order prior to January 1, 2013 pursuant to

former section 22a- 174-20(s)(7) of the Regulations of Connecticut State Agencies

Continue after Januar2211, 2013 to conduct miscellaneous metal parts

coating~ compliance with such a permit or order,

Submit a request to the commissioner to modify the order o~r permit to

include all miscellaneous metal and plastic_parts coating at the premises in

the monthly limit of 1,666 pounds of VOC, or

Submit a request to the commissioner to revoke the order or permit.

Table 20(s)-I I

Metal Parts Coatin~ VOC Content Limits  ̄

Air Dried [

Coatin~ Category ~ VOC/I~s VOC/ ~ VOC/liter--
25

DRAFT

General one-coml~onent 340 280 2.3

General multi-component 340 2_8_0

Camoufla2~ 420 42_Ao

Electric-insulating varnish_ 420 3.5 42~o 3.5

Etching filler 420 42_Ao 3.5

Extreme hig~ 42__Qo 36__QO 3.___0

Extreme performance 42__0 36~o

Heat-resistant 420 3.0

H~g~_per formance 740 74_Ao 6.__2_

architectural

~g~erature 42__Qo 42_~o

Metallic 42~o 42_~o 3.5

Mold-seal 42~o 42_Ao 3.5

Pan backing 42_Ao 42__QO 3.~5

Prefabricated architectural 42~o

multi-coml2onent

Prefabricated architectural 42~o 28~o

one-comaponent

Pretreatment coating 42~o 42~o

Repair and touch-u32 42__Qo 36~0

Silicone release 42__qo 42~0

Solar-absorbent 42__Qo 36_Ao

Vacuum-metalizing 42~o 420

Drum coating,~ 34~o 34~o

exterior

Drum coating~ 42~0 I 42~o

interior

Drum coating, 42__0o 420

reconditioned exterior

Drum coating, 5OO

reconditioned, interior

Table 20(s)-2

Plastic Parts Coati_n~g_V__OC Content Limits

g VOC/liter coating lbs VOC/gal coating

:~onent 28~0 2._Z

lti-component _42~0 3._5_5

sipating coatings and shock- 80~0 6._~7

rformance muIti-com~onent 42_Ao

42_~o

760

ed coating 68~0

ting 80~0

General

General

Electric dissi

free coatin,,

Extreme !

Metallic

Mold-seal

Multi-colored

~tical
26

DRAFT

Table 20(s)-3

A~tomotive-Tra_n_.~portation Plastic Parts Coating VOC Content Limits

Coating Category g VOC/liter coating lbs VOC/gal coating

I. High bake coatings - interior and exterior parts

Flexible primer 54~o

_Non-flexible primer 420

Base coat 52~o

Clear coat 480 4.0

Non-basecoat/clear coat 520

II. Low bake/air dried coatings - exterioroarts

Primer 58_Ao

Basecoat 6o~o

Clearcoat 540 4.5

Non-basecoat/clearcoat 600 5.0 ̧

III. Low bake/air dried coatings - interior 6o__0o

IV. Touchup and repair coating

Table 20(s)-4

Bu~!~,e~ss Machin~.p_l.astic Parts Cq~.~.j_ng_ _V_OC Content Li.m.its

Coating Category g VOC/liter coating lbs VOC/~al coating

I. Primers

III. Texture coat

~ coat

V. Touchup and repair

350

350

35~0

26__Q0

35~0

2.~9

2._~9

2.~2

2.~9

Table 20(s)-5

M0t__o.y Vehicle M_aterials voc Content Limits

g V__QC/liter coating

lbs VOC/~al coating_

vehicle cavity wax 65~0 5.~4

vehicle sealer 65_~o

Motor vel vehicle deadene__£r 65__Q0
27

DRAFT

Motor vehicle gasket&asket sealing

material

Motor vehicle underbody coating

Motor vehicle trunk interior coatin~

Motor vehicle bedliner coating

__Motor vehicle lubricating wax/comEoma_~_d

20~0

65~0

65~0

20~0

70~0

Table 20(s)-6a

AerosPa~.~pe~i~!~ ~oating VOC Conte~t

Ablative coating

Adhesion promoter

Adhesive bondin~ primers:

Cured at 250°F or below

Cured above 250°F

~dhesives:

Commercial interior adhesive

Cyanoacr¥1ate adhesive

Fuel tank adhesive

Nonstructural adhesive

Rocket motor bonding adhesive

Rubber-based adhesive

Structural autoclavable adhesive

Structural nonautoclavable adhesive

Aerospace high-te_m~erature coating

Antichafe coating

Caulking and smoothing compounds

Chemical agent-resistant coating

Clear coating

Commercial exterior aerodxnamic structure primer

~atible substrate 1?rimer

Corrosion prevention compound

Cryogenic flexible primer

Cr¥oprotective coating

Dry lubricative material

Electric or radiation-effect coatin&

Electrostatic discharge and electromagnetic interference

(EMI) coating

Elevated-temperature Skydrol-resistant commercial primer

~olyamide topcoat

Fire-resistant interior coating

Flexible primer

F_l_ight-test coatings_."

Missile or single use aircraft

All other

Fuel-tank coating

Limits

g VOC/liter coating

6OO

89O

850

.1030

760

620

360

89O

850

850

850

660

62~0

85__QO

55~o

72~0

65__Qo

78__~0

71~0

64~5

6O__QO

88__Qo

8o__~o

8o~o

74_Ao

66__QO

80_~0

6_4_O

42~o_

720
28

DRAFT

Insul~ion coverin~g 74_0

Intermediate release coating 75~0

830

Maskants:

BondinKmaskant

Critical use and line sealer maskant

Seal coat maskant

Metallized epoxy coating 740

Mold release 78~0

Optical anti-reflective coating

Part marking coating

Pretreatment coating

Rain erosion-resistant coating

Rocket motor nozzle coating 66~0

Scale inhibitor 880

Screen print ink

Sealants:

Extrudable/roltable/brushable sealant

Sprayable sealant 60__Q0

Silicone insulation material 850

Solid film lubricant

Specialized function coating 89~0

Temporary protective coating 32~o

Thermal control coating 80~0

Wet fastener installation coating 67~5

Table 20(s)-6b

Aerospace Coating VOC Content Limits

_C~pating t~pe ~OC/liter co ati_ng~_

Primer - general aviation rework facilities 540

Exterior primer - la~rge commercial aircraft components 65O

Exterior primer - fully assembled, large commercial aircraft 650

Primer 35~0

T_9~gcoat 420

T~eneral aviation rework facilities 540

Self-priming topcoat 420

_Self-priming topcoat - general aviation rework facilities 540

Type I chemical milling maskant 622

Type II chemical milling maskant t60

Table 20(s)-7

Metal Part~_ Coating VOC Emission Rate Limits

Bak
DRAFT

29

_Coating Cat ego_L.WGeneral one-component

General multi-component

Camouflage

Electric-insulating varnish

Etchin~ filler

Extreme hig_h_7~loss

Extreme performance

Heat-resistant

High performance architectural

High temperature

Metallic

Mold-seal

Pan backing

Prefabricated architectural multicomponent

Prefabricated architectural oneco~oonent

Pretreatment coating

Silicone release

Solar-absorbent

Vacuum-metalizing

Drum coating new exterior

Drum coating=_new, interior

Drum coating, reconditioned exterior

Drum coating, reconditioned, interior

g.VOC/ lb VOC/ g VOC/ lb VOC/

liter solid_.______.As ~ liter soli ~

54~o 4.52 40~0 3.35

54~o 4.52 4o_Ao 3.35

8o_Ao 6.67 8OO 6.67

6.67 8o_~o 6.67

8OO

8o__Qo I

6.67 8O__QO 6.67

6.67 61__QO 5.06

6.67 61__QO 5.06

80O 6.67 5.06

4560 3~ 4560 3~

8o_~o 6.67 8o~o 6.67

800 6.67 6.67

800 6.67 8o__Qo 6.67

8OO 6.67 6.67

800 6.67 4o~o 3.35

800 6.67 400 3.35

800 6.6_~7 8o__Qo 6.67

800 6.67 8o~o 6.67

800 6.67 5.06

800 6.67 8o~o 6.67

540 4.52 54~o 4.52

8o~o 6.67 8o~o 6.67

8o~o 6.67 8o~o 6.67

1170 9.78 1170 9.78

Table 20(s)-8

Plastic Pa ~rt~ ~?~i~g_~OC Emissio~.R~ L~mits

40~0

80~0

_~ O~i.ng Category

General one-component

General multi-component

Electric diss{p_a_ti~s and shock-free

coating~

lbs voc!gal solids

3.35

6.67

8960 74.7

Extreme performance multi-component 80_~0 6.67

Metallic 800 6.67

Mold-sea! 5240 43.7
30

DRAFT

Multi-colored coating~

Optical coating~

Vacuum-metalizing

3040

8960

8960

25.3

74,7

74._57 

Table 20(s)-9

__ Automotive-Transportation Plast_~s Parts Coating VOC Emission Rate Limits

_~_~.t_i_~ g VOC/liter solid.s_~_bs VOC/~alsolid--~-

I. High bake coatings - interior and exterior parts

Flexible primer

Non-flexible primer

Base coat

Clear coat

Non-basecoat!clear coat.

II. Low bake/air dried coatings - exterior parts

Primer

Basecoat_

Clearcoat

Non-basecoat/clearcoat

III. Low bake/air dried coatings - interior parts

IV_ . Touch-up and repair coating

1390

80_~0

1240

1050

1240

1660

1870

1390

1870

1870

2130

11.58

6.67

10.34

8.76

10.34

13.8

15.59

11.58

15.59

15.59

17.72

Table 20(s)-10

Business Ma~.hi_ne Plastic Parts Coating VOC Emission Rate Limits

~gating CategR.~ry_

I. Primers

IL Topcoat

III. Texture coat

~ coat

V. Touchup and repair

g__VOC!liter solid, s

57_~0

570

570

380

570

lbs y.0__C/ al solid_s_

4.80

4.80

4.80

3.14

4.80

Sec. 2. Subdivision (1) of subsection (aa) of section 22a-174-20 of the Regulations of

Connecticut State Agencies is amended to read as follows:

(aa) Record keeping requirements and test methods.

(1) The owner or "operator" of any premise subject to the provisions of subsections (m)

through [(s)] ~) inclusive and subsection (v) of section 22a-174-20 shall maintain daily records

ofalt coatings and diluents used. Such records shall be kept for each individual machine,

operation or coating line. The records must contain the information required below.
DRAFT

(A)

31

description of the coating including the coating name and the coating density in

pounds per gallon;

(B) °°volatile organic compound" content by weight;

(C) water and exempt volatile organic compound content by weight;

(D) non-volatile content by volmne and by weight;

(E) amount of each coating used in gallons;

(F) total amomrt of diluent used for each coating in pounds and in gallons.

See. 3. Subdivisions (2) and (3) of subsection (co) of section 22a-174-20 of the Regulations

of Connecticut State Agencies are amended to read as follows:

[(cc)(2)] 2~ The implementation of an alternative emission reduction plan instead of

compliance with the ["]emissions limitation["] prescribed in ~ one of subsections (m) through

(v)~ [inclusive and] (ee) ~h (kk) of this section must be expressly approved by the

["Commissioner"] commissioner through the issuance of a_permit or an order in accordance with

the provisions of section 22a-174-12 of the Re2~ulations of Cormecticut State A~encies and

approved by the ["administrator"] Administrator in accordance with the provisions of 42

[U.S.C.] USC 7401-7642. After approval, any emissions in excess of those established for each

emission source under the plan will be a violation of these regulations.

[(cc)(3)] 3~! Where it can be shown to the satisfaction of the ["Commissioner"] commissioner

that an emission so~rce cannot be controlled to comply with ~ one of subsections (m) through

(v)~ [inclusive and] (ee) or (ff) throu hgh~(_k!~_) of this section for reasons of technological and

economic feasibility, the ["Commissioner"] commissioner may by permit or order accept a lesser

degree of control upon the submission of satisfactory evidence that the ["]stationary source["]

owner has applied ["]Reasonably Available Control Technology["] and has a plan to develop the

technologies necessary to comply with [the above subsections] the applicable subsection of

subsections ~gr (ff) through (k!~_) of this section and such action is approved

by the [’°administrator"] Administratol~ in accordance with the provisions of 42 [U.S.C.] USC

7401-7642.

Sec. 4. Section 22a-174-20(ii)(3)(A) of the Regulations of Connecticut State Agencies is

amended to read as follows:

(A) The requirements of this subsection shall not apply to the use of cleaning solvent

as follows:

(i) In janitorial cleaning,
DRAFT

(ii)

32

At an aerospace manufacturing and rework operation or a wood furniture coating

operation in accordance with an order or a permit issued pursuant to sections 22a17z~-32(e) and 22a-174-20(cc) of the Regulations of Connecticut State Agencies,

(iii) To perform general solvent cleaning in accordance with an order issued pursuant

to section 22a-174-20(ee) of the Regulations of the Connecticut State Agencies,

(iv) At any aerospace manufacturing and rework facility, provided that cleaning

solvent is used in accordance with the requirements of 40 CFR 63.744, inclusive

of exemptions,

(v) As surface preparation or cleanup solvent in accordance with section 22a-!74-44

of the Regulations of Connecticut State Agencies,

(vi) Where the cleaning solvent is regulated pursuant to section 22a-174-40 of the

Regulations of Connecticut State Agencies,

(vii)

(viii)

To perform industrial solvent cleaning where such cleaning or cleaning solvent is

subject to one of the following subsections of this section: (/) through (y), (ff)

through (t~), or (jj),

In cleaning, including surface preparation .prior to coating, necessary to meet a

standard or specification issued or approved by the United States Department of

Defense, Federal Aviation Administration or other federal government entity.

Any person claiming exemption pursuant to this clause shall maintain records of

the standard or specification,

(ix) Associated with research and development,

(x) Associated with quality control or laboratory testing[,] of coatings, inks or

adhesives

(xi) Associated with medical device manufacturing,

(xii) Associated with pharmaceutical manuthcturing,

(xiii) That exceeds the applicable limit of subdivision (4)(A) of this subsection where

the quantity used does not exceed 55 gallons per any twelve-month rolling

aggregate. Any person claiming exemption pursuant to this clause shall record

and maintain monthly records sufficient to demonstrate compliance with this

exemption, or

(xiv) That exceeds the applicable limit of subdivision (4)(A) of this subsection, if

approved by the commissioner and the Administrator. Any request for approval

shall be made in writing to the commissioner and Administrator and shall include

a description of the cleaning solvent and its VOC content, an explanation of why

the cleaning solvent is necessary, quantification of the amount of the VOC that
DRAFT

33

will be emitted as a result of the use of the noncompliant cleaning solvent and the

time period over which the noncompliant solvent wil! be used.

Sec. 5. Section 22a-174-20 of the Regulations of Connecticut State Agencies is amended by

the addition of new subsection (kk), as follows:

(NEW)

(ld0 Pleasure craft coatings

(1) Definitions. For the purposes of this section, the following definitions apply:

(a) "Airless spray application" means a coating spray application system using high

fluid pressure, without compressed air, to atomize the coating;

(B) "Air-assisted airless spray application" means a coating spray application system

using fluid pressure to atomize the coating and low pressure air to adjust the shape

of the spray pattern;

(0 "Antifouling coating" means a coating applied to the underwater portion of a

pleasure craft to prevent or reduce the attacl~nent of biological organisms;

(D) "Antifouling sealer or tie coat" means a coating applied over biocidal antifouling

coating for the purpose of preventing release of biocides into the environment or

to promote adhesion between air antifouling coating mad a primer or another

antifouling coating;

(E) "As applied" means the composition of coating, excluding water and exempt

compounds, at the time it is applied to a surface, including any solvent, catalyst or

other substance added to the coating;

0) "Capture efficiency" means the ratio of VOC emissions delivered to the control

device to the total VOC emissions resulting from pleasure craft coating and

related clemaing, expressed as a percentage;

"Control device efficiency" memos the ratio of VOC emissions recovered or

destroyed by the control device to the total VOC emissions that are introduced

into the device, expressed as a percentage;

(t4) "Electrostatic application" means a method of applying coating particles or

coating droplets to a grounded surface by electrica!ly charging such particles or

droplets;
DRAFT

34

"Exempt compound" means a carbon compound excluded from the definition of

"volatile organic compound" as defined in section 22a-174-1 of the Regulations

of Connecticut State Agencies;

"Extreme high-gloss coating" means a coating that, when tested by American

Society for Testing Material Test Method D523-08, Standard Test Method for

Specular Gloss, shows a reflectance of 90 or more on a 60 degree meter;

"Finish primer or surfacer" memos a coating applied with a wet film thickness of

less than 10 millimeters prior to the application of a topcoat for purposes of

providing corrosion resistance, adhes!on of subsequent coatings, a moisture

barrier or promotion of a uniform surface necessary for filling in surface

imperfections;

"Flow coating" means a non-atomized technique of applying coating in a fan

pattern to a substrate using a fluid nozzle with no air supplied to the nozzle;

"High build primer or surfacer" means a coating applied with a wet film thickness

of 10 millimeters or more prior to the application of a topcoat for purposes of

providing corrosion resistance, adhesion of subsequent coatings, a moisture

barrier or promotion of a uniform surface necessary for filling in surface

imperfections;

"High gloss coating" means a coating that, when tested by American Society for

Testing Material Test Method D523-08, Standard Test Method for Specular

Gloss, shows a reflectance of 85 or more on a 60 degree meter;

(o)

(P)

(Q)

"HVLP spray application" means to apply a coating using a coating application

system that uses lower air pressure and higher volume than conventional air

atomized spray systems, where the manufacturer has represented that the system

is HVLP by affixing a permanent label or through representations on the

packaging or other product literature;

"Overall control efficiency" means the product of the capture efficiency and the

control device efficiency;

"Pleasure craft" means any marine or fresh~vater vessel manufactured or operated

primarily for recreational purposes;

(R) "Pleasure craft coating" means any marine coating, except unsaturated polyester

resin (fiberglass), applied to a pleasure craft or to parts and components of a

pleasure craft;

(s) "Pretreatment wash primer" means a coating, containing at least O. 1 percent acid

by weight and no more than 25 percent solids by weight, that is used to provide

surface etching and is applied directly to fiberglass and metal surfaces to provide

corrosion resistance and adhesion of subsequent coatings;
DRAFT

35

(T) "Related cleaning" means the removal of uncured coatings, coating residue, and

contaminants from:

(u)

(i)

(ii)

(iii)

Pleasure craft or parts and components of pleasure craft prior to the

application of coatings,

Pleasure re:aft or parts and components of pleasure craft between coating

applications, or

Transfer lines, storage tanks, spray booths, and coating application

equipment; and

"Transfer efficiency" means the portion of coating solids that adheres to the

pleasure craft surface during the application process, expressed as a percentage of

the total volume of coating solids delivered by the applicator.

(2) Applicability.

(A) Except as provided in subdivision (3) of this subsection, the provisions of this

subsection apply to the owner or operator of any marina, boat yard, or other

premises where pleasure craft coating is applied for commercial purposes at the

direction of such owner or operator, if:

(i) Such owner or operator was subject to subsection (s) of this section prior

to January 1, 2013, or

(ii) Such owner or operator purchases for use in all pleasure craft coating and

related cleaning at the premises 855 gallons or more of coatings and

cleaning solvents in aggregate per rolling 12-month period;

(B) An owner or operator subject to this subsection shall:

(i) For a source operating prior to January 1, 2013, comply with the

requirements of this subsection no later than January 1, 2013, or

(ii) For a source that commences operation after January 1, 2013, comply with

the requirements of this subsection upon corrm~encing operation; and

(c) Any owner or operator subject to this subsection shall remain subject to this

subsection.

(3) Exemptions and exceptions.

(A) Except as provided in subdivision (7) of this subsection, the requirements of this

subsection shall not apply to any of the fol!owing activities, and the VOC

emissions resulting from the following activities shall not be included in

determinations pursuant to subdivision (2) or (4)(E) of this subsection:
36

DRAFT

(i) Coating and cleanin~ subject to one of the following subsections of this

section: (1) through (s) and (bh) through (j j),

(ii) Coating and associated surface preparation and cleanup subject to section

22a-174-41 of the Regulations of Connecticut State Agencies,

(iii) Coating applied with a hand-held aerosol can,

(iv) Application of adhesive, sealant, adhesive primer or sealant primer

regulated by section 22a-174-44 of the Regulations of CoImecticut State

Agencies,

(v) Coating applied to test materials, test panels and coupons in research and

development, quality control or performance testing,

(vi) Use of coatings containing VOC at concentrations less than 1.0 percent by

weight, or

(vii) Use of cleaning solvents containing VOC at concentrations less than 5.0

percent by weight.

(B) The requirements of subdivision (5) of this subsection shall not apply to the

application of an extreme high gloss coating.

(0 An owner or operator may use in aggregate in any 12 consecutive months no

more than 55 gallons of pleasure craft coatings that exceed the VOC content

limits or emission limits of subdivision (4) of this subsection.

(4) On and after January 1, 2013, no owner or operator of a pleasure craft coating operation

shall apply any coating, inclusive of any VOC-containing material added to the original coating

supplied by the manuihcturer, unless the owner or operator controls emissions of VOCs in

accordance with subparagraph (A), (B), (C), (D) or (E) of this subdivision. If more than one

emission limit or emission rate applies in a particular situation, then the least restrictive limit or

rate shall apply. An owner or operator shall:

(A) Use only coatings that have an as applied VOC content no greater than the

applicable level in Table 20(kk)-I;

(B) Use a combination oflow-VOC coatings and add-on air pollution control

equipment to achieve a VOC emission rate no greater than the applicable level in

Table 20(kk)-2;

(0 Install, operate and maintain according to the manufacturer’s recommendations

air pollution control equipment with an overall control efficiency of at least 90%;
DRAFT

(D)

(E)

37

Use an alternative means, achieving a level of control equivalent to subparagraph

(A), (B) or (C) of this subdivision, requested from and approved by the

commissioner in accordance with subsection (cc) of this section; and

Limit the total potential VOC emissions from all pleasure craft coating operations

and related cleaning by permit or order of the commissioner to 1,666 pounds or

less in any calendar month.

(5) Application methods. Except as provided in subdivision (3) of this subsection, an owner

or operator shall not apply a VOC-containing coating to a pleasure craft or to a part or

component of a pleasure craft unless the coating is applied by one of the methods identified in

subparagraphs (A) through (F) of this., subdivision using equipment operated in accordance with

the specifications of the equipment manufacturer:

(A) Electrostatic application;

(B) HVLP spray application;

(C) Airless spray application;

(D) Air-assisted airless spray application;

(E) Hand application; or

(F) Any other coating application method capable of achieving a transfer efficiency

equivalent to or better than that provided by HVLP spray application. Any

coating operation using an application method pursuant to this subparagraph shall

maintain records demonstrating the transfer efficiency achieved.

(6) Work practices. Each owner or operator shall use the following work practices:

(A) New and used VOC-containing coating, diluent or cleaning solvent, including a

coating mixed on the premises, shall be stored in a nonabsorbent, non-leaking

container. Such a comainer shall be kept closed at all times except when the

container is being filled, emptied or is otherwise actively in use;

(B) Spills and leaks of VOC-containing coating, diluent or cleaning solvent shall be

minimized. Any leaked or spilled VOC-containing coating, diluent or cleaning

solvent shall be contained, absorbed and removed immediately;

(c) Absorbent applicators, such as cloth and paper, which are moistened with a VOCcontaining coating or solvent, shall be stored in a closed, nonabsorbent, nonleaking container for disposal or recycling; and

(D) VOC-containing coating, diluent and cleaning solvent shall be conveyed from one

!ocation to another in a closed container or pipe.
DICAFT

(7) Records.

(8)

38

(A) Except as provided in subparagraphs (B) and (C), an owner or operator shall

maintain records of information sufficient to determine compliance with the

applicable requirements of this subsection, including, at a minimum, the

following information for each calendar month:

(i) Name and description of each coating and cleaning solvent,

(ii) VOC content of each coating and diluent, as applied, and the associated

calculations,

(iii) VOC content of each coating or cleaning solvent, as supplied,

(iv) The amount of each coating and cleaning solvent:

(I) Purchased, or

(II) Used,

(v) A Material Safety Data Sheet, Enviromnental Data Sheet, Certified

Product Data Sheet, or an equivalent data sheet for each coating and

cleaning solvent,

(vi) Documentation of control device efficiency and capture efficiency, if

applicable, using an applicable EPA reference method or alternate method

as approved by the commissioner and the Administrator, and

(vii) Date and type of maintenance performed on air pollution control

equipment, if applicable.

(B) Any owner or operator who does not meet the applicability thresholds provided in

subdivision (2)(A) of this subsection shall maintain either material purchase or

actual usage records to verify that this subsection does not apply to such owner or

operator.

(C) An owner or operator operating pursuant to an exception or exemption in

subdivision (3) of this subsection shall maintain records sufficient to verify the

applicability of the exception or exemption.

(D) All records made pursuant to this subdivision shall be:

(i) Made available to the commissioner to inspect and copy upon request, and

(ii) Maintained tbr five years from the date such record is created.

Compliance procedures.
DRAFT

(A)

(c)

(D)

39

The VOC content limits of Table 20(kk)-1 apply to the volume of coating as

applied, detenzained using the following equation:

VOC Content = (Ws - Ww-Wes)/(Vm - Vw - Ves)

Where: Ws = weight of volatile compounds in grams

Ww = weight of water in grams

Wes = weight of exempt compounds in grains

Vm = volume of coating in liters

Vw = volume of water in liters

Ves = volume of exempt compounds in liters

The VOC emission rate limits of Table 20(kk)-2 apply to the mass of VOC

emitted per volume of coating solids, as applied.

To determine the properties of a coating or components thereof in order to

perform the calculations required pursuant to subparagraph (A) of this subdivision

or to verify calculations based on the manufacturer’s formulation data, the VOC

and solids content of all coatings shall be determined using 40 CFR 60, Appendix

A, Reference Method 24 or an equivalent method. In the case of a dispute, the

VOC content detemained using Reference Method 24 shall control, unless a

person is able to demonstrate to the satisfaction of the commissioner and the

Administrator that the manufacturer’s formulation data are correct.

Where a VOC content limit or emissions rate is provided in metric units and

equivalent English units, the limit or rate in metric units defines the standard. The

English units are provided for information only.

A pleasure craft coating shall be defined and categorized based on the

manufacturer’s representations as set out on the container or label or in

information provided by the manufacturer of such a pleasure craft coating.

Table 20(kk)-I

Pleasure Craft Coating VOC Content Limits

Coating Category g VOC/liter coating Ibs VOC/gal coating

Extreme high gloss topcoat 600 5.0

High gloss topcoat 420 3.5

Pretreatment wash primer 78O 6.5

Finish primer or surfacer Effective until Effective until

December 31, 2015: December 31,2015:

600 5.0

Effective January 1, Effective January 1,
DRAFT

High b~ild primer or surfacer

Aluminum substrate antifouling coating

Other substrate antifouling coating

Antifouling sealant or tie coat

All other pleasure craft surface coatings for

metal or plastic __

20!6:420

340

56O

4OO

420

420

2016:3.5

2.8

4.7

3.3

3.5

3.5

4O

Table 20(kk)-2

Pleasure Craft Surface Coatil VOC Emission Rate Limits

Coatin~ory VOC/liter solids IbsVOC/galsolids

Extreme high gloss topcoat 1100 9.2

High gloss topcoat 8OO 6.7

Pretreatment wash primer 6670 55.6

Finish primer or surfacer Effective until EffEctive until

December 31, 2015: December 31,

1870 2015:15.59

Effective January 1, Effective January

2016:800 t, 2016:6.7

High build primer or surfacer 55O 4.6

Aluminum substrate antifouling coating 1530 12.8

Other substrate antifouling coating 764 6.4

Antifouling sealer or tie coat 800 6.7

All other pleasure craft surface coatings for 8OO 6.7

metal or plastic

Statement of purpose: The main purpose of this proposal is to enhance existing and add new

requirements to control volatile organic compound (VOC) emissions from two types of surface

coating operations. VOC emissions are a precursor to groundqevel ozone, a harmful air

pollutant. The U.S. Enviromnentat Protection Agency (EPA) has designated the entire state as

nonattairament for the 2008 ozone national ambient air quality standard (NAAQS) and has

initiated the statutorily required review of the NAAQS to be completed in 2013. The proposed

limitations on VOC emissions will assist Connecticut to attain and maintain the federal ozone

NAAQS.

The Department of Energy and Environmental Protection (DEEP) currently regulates VOC

emissions from metal parts coating under section 22a- 174-20 of the Regulations of Connecticut

State Agencies (RCSA). In response to EPA guidance, DEEP is proposing to add more stringent

VOC control requirements for metal parts and to broaden the applicability to include coating of

plastic parts. (Section 1)

Also in accord with EPA guidance, DEEP is proposing new requirements for addition to RCSA

section 22a-174-20 to limit VOC emissions from pleasure craft coating. Owners of marinas and
41

DRAFT

boat yards that coat pleasure craf~ will be required to meet the VOC content limits for coatings

and keep records of coatings and solvents purchased. (Section 5)

The requirements for both miscellaneous parts coating and pleasure craft coating include VOC

content limits for coatings applied; work practices that limit evaporation and waste of coatings

and solvents; coating application methods; and record keeping requirements.

Elements of the proposal aside from the parts and pleasure craft coating are minor revisions to

address the interaction of the revised and new requirements with other subsections of RCSA

section 22a-174-20. Such revisions are as follows:

Removing redundant record keeping requirements for owners and operators of

miscellaneous metal and plastic parts coating facilities (Section 2);

~ Removing an artificial distinction between the use of permits and orders as the

enforceable mechanisms for alternative emissions control scenarios for sources of volatile

organic compound emissions (Section 3); and

Making a minor clarification to the industrial solvent cleaning requirements of subsection

(ii) of RCSA section 22a- 174-20. (Section 4)
Attachment F

Report of the Legislative Commissioners’ Office
1

The Connecticut General Assembly 

Legislative Commissioners’ Office 

Edwin J. Maley, Jr. 

Commissioner

William A. Hamzy 

Commissioner 

Larry G. J. Shapiro 

Director 

Legislative Office Building 

Suite 5500 

Hartford, Connecticut 

06106-1591 

(860) 240-8410 

fax (860) 240-8414 

e-mail: lco@cga.ct.gov 

Memorandum 

To: Legislative Regulation Review Committee 

From: Legislative Commissioners’ Office 

Committee Meeting Date: October 23, 2012 

Regulation No: 2012-24A 

Agency: Department of Energy and Environmental Protection 

Subject Matter: Air Quality Regulations Concerning Certain Coating 

Operations 

Statutory Authority: 

 (copy attached) 

22a-174 

Yes or No 

Mandatory Y 

Federal Requirement Y 

Permissive N 

For the Committee's Information: 

This is a resubmittal of regulations that were rejected without prejudice at the committee's 

meeting on July 24, 2012. The resubmittal addresses the substantive concerns and 

technical corrections noted in the July 24, 2012 report. There are additional technical 

corrections, as noted in the instant report. 

Substantive Concerns:
2

Technical Corrections: 

1. On page 14, in subdivision (2)(A)(i), "as was in effect" should be "that was in effect", 

for clarity. 

2. On page 14, in subdivision (2)(A)(ii), "solvents in aggregate" should be "solvents in the 

aggregate", for clarity. 
3

Recommendation:

X Approval in whole 

X with technical corrections 

with deletions 

with substitute pages 

Disapproval in whole or in part 

Rejection without prejudice 

Reviewed by: Bradford M. Towson / Angela Rehm 

Date: October 10, 2012 
4

Sec. 22a-174. (Formerly Sec. 19-508). Powers of the commissioner. Regulations. 

Fees. Exemptions. General permits. Appeal of commissioner's action re permit 

applications. (a) The commissioner, in the manner provided in subdivision (1) of section 

22a-6, shall have the power to formulate, adopt, amend and repeal regulations to control 

and prohibit air pollution throughout the state or in such areas of the state as are affected 

thereby, which regulations shall be consistent with the federal Air Pollution Control Act 

and which qualify the state and its municipalities for available federal grants. Any person 

heard at the public hearing on any such regulation shall be given written notice of the 

determination of the commissioner. 

(b) The commissioner shall have the power to (1) enter into contracts with technical 

consultants, including, but not limited to, nonprofit corporations created for the purpose of 

facilitating the state's implementation of multistate air pollution control programs, for 

special studies, advice and assistance; to consult with and advise and exchange information 

with other departments or agencies of the state; and (2) serve on the board of directors of a 

nonprofit corporation, including, but not limited to, a nonprofit corporation created for the 

purpose of facilitating the state's implementation of multistate air pollution control 

programs. 

(c) The commissioner shall have the power, in accordance with regulations adopted by 

him, (1) to require that a person, before undertaking the construction, installation, 

enlargement or establishment of a new air contaminant source specified in the regulations 

adopted under subsection (a) of this section, submit to him plans, specifications and such 

information as he deems reasonably necessary relating to the construction, installation, 

enlargement, or establishment of such new air contaminant source; (2) to issue a permit 

approving such plans and specifications and permitting the construction, installation, 

enlargement or establishment of the new air contaminant source in accordance with such 

plans, or to issue an order requiring that such plans and specifications be modified as a 

condition to his approving them and issuing a permit allowing such construction, 

installation, enlargement or establishment in accordance therewith, or to issue an order 

rejecting such plans and specifications and prohibiting construction, installation, 

enlargement or establishment of a new air contaminant source in accordance with the plans 

and specifications submitted; (3) to require periodic inspection and maintenance of 

combustion equipment and other sources of air pollution; (4) to require any person to 

maintain such records relating to air pollution or to the operation of facilities designed to 

abate air pollution as he deems necessary to carry out the provisions of this chapter and 

section 14-164c; (5) to require that a person in control of an air contaminant source 

specified in the regulations adopted under subsection (a), obtain a permit to operate such 

source if the source (A) is subject to any regulations adopted by the commissioner 

concerning high risk hazardous air pollutants, (B) burns waste oil, (C) is allowed by the 
5

commissioner, pursuant to regulations adopted under subsection (a), to exceed emission 

limits for sulfur compounds, (D) is issued an order pursuant to section 22a-178, or (E) 

violates any provision of this chapter, or any regulation, order or permit adopted or issued 

thereunder; (6) to require that a person in control of an air contaminant source who is not 

required to obtain a permit pursuant to this subsection register with him and provide such 

information as he deems necessary to maintain his inventory of air pollution sources and 

the commissioner may require renewal of such registration at intervals he deems necessary 

to maintain such inventory; (7) to require a permit for any source regulated under the 

federal Clean Air Act Amendments of 1990, P.L. 101-549; (8) to refuse to issue a permit if 

the Environmental Protection Agency objects to its issuance in a timely manner under Title 

V of the federal Clean Air Act Amendments of 1990; and (9) notwithstanding any 

regulation adopted under this chapter, to require that any source permitted under Title V of 

the federal Clean Air Act Amendments of 1990 shall comply with all applicable standards 

set forth in the Code of Federal Regulations, Title 40, Parts 51, 52, 59, 60, 61, 63, 68, 70, 

72 to 78, inclusive, and 82, as amended from time to time. 

(d) The commissioner shall have all incidental powers necessary to carry out the 

purposes of this chapter and section 14-164c. 

(e) As used in this subsection, "contiguous" means abutting or adjoining without 

consideration of the actual or projected existence of roadways, walkways, plazas, parks or 

other minor intervening features; "indirect source" means any building, structure, facility, 

installation or combination thereof, that has or leads to associated activity as a result of 

which any air pollutant is or may be emitted. The commissioner shall not require the 

submission of plans and specifications under indirect source regulations adopted pursuant 

to subdivisions (1) and (2) of subsection (c) of this section for proposed construction to be 

undertaken within a redevelopment area or urban renewal project, as defined in chapter 

130, provided (1) the proposed construction is pursuant to a plan for such redevelopment 

area or urban renewal project adopted pursuant to section 8-127 prior to October 1, 1974, 

or to a modification of such plan, (2) the proposed construction is part of a contiguous, 

single purpose or multipurpose development or developments and (3) site clearance or 

construction had commenced on a portion of the site of such development or developments 

prior to October 1, 1974, nor shall the commissioner issue any order pursuant to 

subdivision (1) of subsection (c) of this section pertaining to the enforcement of indirect 

source regulations with respect to such proposed construction within such redevelopment 

areas and urban renewal projects. In the event that the modification of any such plan after 

October 1, 1974, would result in the proposed construction generating substantially more 

motor vehicle traffic than would have been generated prior to such modification, the 

submission of plans and specifications shall be required for such proposed modification. 

The commissioner shall not require the renewal of an indirect source operating permit 
6

issued in accordance with subsection (c) of this section unless such indirect source no 

longer conforms with plans, specifications or other information submitted to said 

commissioner in accordance with said subsection (c). 

(f) The commissioner shall allow the open burning of brush on residential property, 

provided the burning is conducted by the resident of the property or the agent of the 

resident and a permit for such burning is obtained from the local open burning official of 

the municipality in which the property is located, and the open burning of brush in 

municipal landfills, transfer stations and municipal recycling centers, provided a permit for 

such burning is obtained from the fire marshal of the municipality where the facility is 

located, except that no open burning of brush shall occur (1) when national or state 

ambient air quality standards may be exceeded; (2) where a hazardous health condition 

might be created; (3) when the forest fire danger in the area is identified by the 

commissioner as extreme and where woodland or grass land is within one hundred feet of 

the proposed burn; (4) where there is an advisory from the commissioner of any air 

pollution episode; (5) where prohibited by an ordinance of the municipality; and (6) in the 

case of a municipal landfill, when such landfill is within an area designated as a hot spot 

on the open burning map prepared by the commissioner. A permit for the burning of brush 

at any municipal landfill, municipal transfer station or municipal recycling center shall be 

issued no more than six times in any calendar year. The proposed permit to burn brush at 

any municipal landfill, municipal transfer station or municipal recycling center shall be 

submitted to the commissioner by the fire marshal, with the approval of the chief elected 

official of the municipality in which the municipal landfill, municipal transfer station or 

municipal recycling center is located. The commissioner shall approve or disapprove the 

fire marshal's proposed permitting of burning of brush at a municipal landfill, municipal 

transfer station or municipal recycling center within a reasonable time of the filing of such 

application. The burning of leaves, demolition waste or other solid waste deposited in such 

landfill shall be prohibited. The burning of nonprocessed wood for campfires and bonfires 

is not prohibited if the burning is conducted so as not to create a nuisance and in 

accordance with any restrictions imposed on such burning. Nothing in this subsection or in 

any regulation adopted pursuant to this subsection shall affect the power of any 

municipality to regulate or ban the open burning of brush within its boundaries for any 

purpose. Notwithstanding any other provision of this section, fire breaks for the purpose of 

controlling forest fires and controlled fires in salt water marshes to forestall uncontrolled 

fires are not prohibited. Open burning may be engaged in for any of the following purposes 

if the open burning official with jurisdiction over the area where the burning will occur 

issues an open burning permit: Fire-training exercises; eradication or control of insect 

infestations or disease; agricultural purposes; clearing vegetative debris following a natural 

disaster; and vegetative management or enhancement of wildlife habitat or ecological 

sustainability on municipal property or on any privately owned property permanently 
7

dedicated as open space. Open burning for such purposes on state property may be 

engaged in with the written approval of the commissioner. Local burning officials 

nominated for the purposes of this subsection shall be nominated only by the chief 

executive officer of the municipality in which the official will serve and shall be certified 

by the commissioner. The chief executive officer may revoke the nomination. The 

commissioner may adopt regulations, in accordance with the provisions of chapter 54, 

governing open burning and may authorize or prohibit open burning consistent with this 

section. The regulations may require the payment of an application fee and inspection fee 

and may establish a certification procedure for local burning officials. 

(g) The commissioner shall require, by regulations adopted in accordance with the 

provisions of chapter 54, the payment of a permit application fee sufficient to cover the 

reasonable costs of reviewing and acting upon an application for, and monitoring 

compliance with the terms and conditions of, any state or federal permit, license, order, 

certificate or approval required pursuant to this section. Any person obtaining a permit, 

pursuant to said regulations, for the construction or operation of a source of air pollution or 

for modification to an existing source of air pollution shall submit a permit fee of twice the 

amount of the fee established by regulations in effect on July 1, 1990. The commissioner 

shall require the payment of a permit application fee of two hundred dollars. 

(h) The commissioner may require, by regulations adopted in accordance with the 

provisions of chapter 54, payment of a fee by the owner or operator of a source of air 

pollution, sufficient to cover the reasonable cost of a visual test of an air pollution control 

device through the use of a dust compound in the detection of leaks in such device, or the 

monitoring of such test, provided such fee may not exceed the average cost to the 

department for the conduct or monitoring of such tests plus ten per cent of such average 

cost. Except as specified in section 22a-27u, all payments received by the commissioner 

pursuant to this subsection shall be deposited in the General Fund and credited to the 

appropriations of the Department of Energy and Environmental Protection in accordance 

with the provisions of section 4-86. 

(i) Notwithstanding the provisions of subsections (g) and (h) of this section, no 

municipality shall be required to pay more than fifty per cent of any fee established by the 

commissioner pursuant to said subsections. 

(j) Fees or increased fees prescribed by this section shall not be applicable to residential 

property. 

(k) (1) The commissioner may issue a general permit with respect to a category of new 

or existing stationary air pollution sources, except with respect to a source which is already 

covered by an individual permit, provided the general permit is not inconsistent with the 
8

federal Clean Air Act, as amended in 1990, 42 USC, Sections 7401 et seq., and as it may 

be further amended from time to time. Any person conducting an activity for which a 

general permit has been issued shall not be required to obtain an individual permit under 

this section, except as provided in subdivision (5) of this subsection. The general permit 

may regulate a category of sources which, whether or not requiring a permit under the 

federal Clean Air Act, (A) involve the same or substantially similar types of operations or 

substances, (B) require the same types of pollution control equipment or other operating 

conditions, standards or limitations, and (C) require the same or similar monitoring, and 

which, in the opinion of the commissioner, are more appropriately controlled under a 

general permit than under an individual permit. The general permit may require that any 

person proposing to conduct any activity under the general permit register such activity, 

including obtaining approval from the commissioner, before the general permit becomes 

effective as to such activity, and may include such other conditions as the commissioner 

deems appropriate, including, but not limited to, management practices and verification 

and reporting requirements. Any such reports shall be made available to the public by the 

commissioner. The commissioner shall grant an application for approval under a general 

permit without repeating the notice and comment procedures provided under subdivision 

(2) of this subsection, and such a grant shall not be subject to judicial review under 

subdivision (4) of this subsection. Registrations and applications for approval under the 

general permit shall be submitted on forms prescribed by the commissioner; application 

forms concerning activities regulated under the federal Clean Air Act shall require that the 

applicant provide such information as may be required by that act. The commissioner shall 

prepare, and annually amend, a list of holders of general permits under this section, which 

list shall be made available to the public. 

(2) Notwithstanding any other procedures in this chapter, any regulations adopted 

thereunder, and chapter 54, the commissioner may issue a general permit in accordance 

with the following procedures: (A) The commissioner shall publish in a newspaper, having 

a substantial circulation in the affected area or areas, notice of (i) intent to issue a general 

permit, (ii) the right to inspect the proposed general permit, (iii) the opportunity to submit 

written comments thereon, and (iv) the right to a public hearing if, within the comment 

period, the commissioner receives a petition signed by at least twenty-five persons 

provided the notice shall state that the right to a public hearing may be exercised upon 

request of any person if the permit regulates an activity which is subject to provisions of 

the federal Clean Air Act; (B) the administrator of the United States Environmental 

Protection Agency and any states affected by the general permit shall be given notice as 

may be required by the federal Clean Air Act; (C) the commissioner shall allow a comment 

period of thirty days following publication of notice under subparagraph (A) of this 

subdivision during which interested persons may submit written comments concerning the 

permit to the commissioner; (D) the commissioner shall not issue the general permit until 
9

after the comment period and the public hearing, if one is held; (E) the commissioner shall 

publish notice of any general permit issued in a newspaper having a substantial circulation 

in the affected area or areas; and (F) summary suspension may be ordered in accordance 

with subsection (c) of section 4-182. Any person may request that the commissioner issue, 

modify, revoke or suspend a general permit in accordance with this subsection. 

(3) Any general permit under this subsection shall be issued for a fixed term. A general 

permit covering an activity regulated under the federal Clean Air Act shall be issued for a 

term of no more than five years. A general permit covering an activity regulated under the 

federal Clean Air Act shall contain such additional conditions as may be required by that 

act. 

(4) Notwithstanding any other provision of this chapter and chapter 54, with respect to a 

general permit concerning activities regulated under the federal Clean Air Act, any person 

who submitted timely comments thereon may appeal the issuance of such permit to the 

superior court in accordance with the provisions of section 4-183. Such appeal shall have 

precedence in the order of trial as provided in section 52-192. 

(5) Subsequent to the issuance of a general permit, the commissioner may require a 

person whose activity is or may be covered by the general permit to apply for and obtain 

an individual permit pursuant to this chapter if he determines that an individual permit 

would better protect the land, air and waters of the state from pollution. The commissioner 

may require an individual permit under this subdivision in cases including, but not limited 

to, the following: (A) The permittee is not in compliance with the conditions of the general 

permit; (B) a change has occurred in the availability of demonstrated technology or 

practices for the control or abatement of pollution applicable to the permitted activity; (C) 

circumstances have changed since the time the general permit was issued so that the 

permitted activity is no longer appropriately controlled under the general permit, or a 

temporary or permanent reduction or elimination of the permitted activity is necessary; or 

(D) a relevant change has occurred in the applicability of the federal Clean Air Act. In 

making the determination to require an individual permit, the commissioner may consider 

the location, character and size of the source and any other relevant factors. The 

commissioner may require an individual permit under this subdivision only if the person 

whose activity is covered by the general permit has been notified in writing that an 

individual permit is required. The notice shall include a brief statement of the reasons for 

requiring an individual permit, an application form, a statement setting a time for the 

person to file the application and a statement that the general permit as it applies to such 

person shall automatically terminate on the effective date of the individual permit. Such 

person shall forthwith apply for, and use best efforts to obtain, the individual permit. Any 

person may petition the commissioner to take action under this subdivision. 
10

(6) The commissioner may adopt regulations, in accordance with the provisions of 

chapter 54, to carry out the purposes of this subsection. 

(l) In any proceeding on an application for a permit which is required under 42 USC 

7661a, the applicant, and any other person entitled under said section to obtain judicial 

review of the commissioner's final action on such application may appeal such action in 

accordance with the provisions of section 4-183. 

(m) The commissioner shall not issue a permit for an asphalt batch plant or continuous 

mix facility under the provisions of this section until July 1, 2004, unless the commissioner 

determines that the issuance of the permit will result in an improvement of environmental 

performance of an existing asphalt batch plant or continuous mix plant. The provisions of 

this section shall apply to any application pending on May 5, 1998. Nothing in this section 

shall apply to applications for upgrading, replacing, consolidating or otherwise altering the 

physical plant of an existing facility provided such upgrade, replacement, consolidation or 

alteration results in an improvement of environmental performance or in reduced total 

emissions of air pollutants. 
Attachment G

Regulatory Assessment Document
Regulatory Assessment Document

Amendment of RCSA Section 22a-174-22a-174-20(s) and 

Adoption of RCSA Section 22a-174-22a-174-20(kk)

Revised November 23, 2011

Prepared by

Robin Baena

April Desclos

Merrily A. Gere

The Connecticut Department of Energy and Environmental Protection (CTDEEP) has prepared 

this regulatory assessment document (RAD) to explain the origin of a proposal to amend 

subsection (s) of section 22a-174-20 of the Regulations of Connecticut State Agencies (RCSA) 

and to adopt subsection (kk) of RCSA section 22a-174-20. Both subsections (s) and (kk) address 

emissions of volatile organic compounds (VOCs) from surface coating activities. This RAD 

describes the motivation for this proposal, the structure of the proposal, the design considerations 

pertinent to the proposal and the expected air quality benefits of the proposal. 

This RAD is intended to help both CTDEEP staff and the regulated community understand what 

is intended by the proposal. However, if any statement in this document is found to be contrary 

to a final adopted regulation, the regulatory language shall control. 

I. Introduction and Background

Coatings or paints used in surface coating industries are a significant source of emissions of 

volatile organic compounds (VOCs). In the presence of sunlight, VOCs and nitrogen oxides

(NOx) undergo a series of chemical reactions to form ozone. VOC emissions from coatings can 

also lead to the formation of particulate matter (PM). Ozone and PM are two of the most serious 

air pollutants in Connecticut. Ozone is a strong oxidizer that irritates the respiratory system, 

leading to a variety of adverse health effects. High ground-level ozone concentrations may also 

aggravate chronic lung diseases like emphysema and bronchitis, reduce the immune system's 

ability to fight off bacterial infections in the respiratory system, or cause permanent lung 

damage. Ground-level ozone also damages plant life and property. PM exposure has also been 

associated with a wide range of adverse health impacts, including hospitalization and premature 

death. 

To protect people from the harmful effects of exposure to ozone and PM, the U.S. Environmental 

Protection Agency (EPA) has established national ambient air quality standards (NAAQS) for 

these pollutants. All of Connecticut is classified as nonattainment for the ozone standard 

because the monitored air quality does not comply with federal air quality standards, and 

Fairfield and New Haven counties are designated as nonattainment for fine particulate matter. 

For each nonattainment area, CTDEEP has developed a plan that describes how the state will 

attain the ambient air quality standards, which generally involves implementing a suite of 
2

measures that will reduce direct emissions of the pollutant of concern or reduce emissions of 

precursor pollutants. 

In February 2008, CTDEEP submitted a plan to EPA demonstrating how Connecticut would 

attain and maintain the 1997 8-hour ozone NAAQS. As required by Section 172(c)(1) of the 

Clean Air Act (CAA), Connecticut’s 8-hour ozone NAAQS plan includes reasonably available 

control technology (RACT) requirements for emissions sources that contribute to nonattainment. 

EPA defines RACT as “the lowest emission limitation that a particular source is capable of 

meeting by the application of control technology that is reasonably available considering 

technological and economic feasibility” (44 FR 53761; September 17, 1979). CAA section 

182(b)(2)(A) requires that for certain nonattainment areas, states revise their State 

Implementation Plans (SIPs) to include RACT for each category of VOC sources for which EPA 

has published a control techniques guideline (CTG). 

In developing a CTG, EPA evaluates sources of VOC emissions, the available approaches for 

reducing emissions, and the cost of such approaches. Based on this information, EPA 

recommends a RACT level of control. States use CTG recommendations to inform their own 

determination as to what constitutes RACT in their particular nonattainment areas, or states may 

implement other approaches that are consistent with the CAA and EPA regulations to impose a 

level of control at least as stringent as that recommended in a CTG.

EPA published a CTG in September 2008 to provide state and local air pollution control 

authorities with information for determining RACT for VOC emissions from miscellaneous 

metal and plastic parts coating operations.1 Connecticut is proposing revisions to section 22a174-20 of the Regulations of Connecticut State Agencies (RCSA) to adopt a RACT level of 

control as established in the 2008 CTG for the miscellaneous metal and plastic parts coating 

category. The 2008 CTG updates a 1978 CTG addressing emissions from miscellaneous metal 

parts coating,2 which CTDEEP first adopted as RCSA section 22a-174-20(s) in 1980 and revised 

in 1993 to increase compliance flexibility. CTDEEP is proposing to revise subsection (s) to 

include plastic parts coating and update the metal parts coating requirements. EPA includes 

pleasure craft coating operations within the metal and plastic parts coatings category in the 2008 

CTG. Recognizing the differences in parts coating operations and pleasure craft coating, 

CTDEEP is proposing to address pleasure craft coating with regulatory requirements separate 

from those applying to metal and plastic parts coating, namely new subsection (kk) of RCSA 

section 22a-174-20. 

II. Legal Authority & Basis

Section 22a-174(a) of the Connecticut General Statutes (CGS) authorizes the commissioner to 

adopt and amend air pollution control regulations for the State of Connecticut. RSCA Section 

22a-174-20 has been adopted and amended under this authority for the purpose of controlling 

VOC emissions from identified categories of air emissions. This proposal to amend subsection 

(s) and adopt subsection (kk) is made under the authority of the CGS section 22a-174.

 

1 EPA. Control Techniques Guideline for Miscellaneous Metal and Plastic Parts Coatings. EPA-453/R-08-

0373. October 7, 2008. 

2 EPA. Control of Volatile Organic Emissions from Existing Stationary Sources Volume VI Surface Coating 

of Miscellaneous Metal Parts and Products. EPA 450/2-78-015. June 1978. 
3

The 2008 CTG for miscellaneous metal and plastic parts coating forms the basis for the revisions 

proposed to subsection (s) and for new subsection (kk) of RCSA section 22a-174-20. 

III. Description of Regulatory Requirements

This section describes the basic elements of proposed subsections (s) and (kk) of RCSA section 

22a-174-20. Information about the considerations underlying each element is provided in 

Section IV. 

People operating potentially regulated coating operations should keep in mind that RCSA section 

22a-174-20 applies to an operation or activity regardless of the operation’s status under the air 

quality permit programs. Operations that are below the potential emissions thresholds of RCSA 

section 22a-174-3a, Connecticut’s new source review program regulation, may be subject to 

requirements under RCSA section 22a-174-20. Contrarily, an operation for which the owner has 

obtained a new source review permit may need to comply with RCSA section 22a-174-20. The 

applicability threshold for the CTG-based subsections of RCSA section 22a-174-20 is typically 

equivalent to three tons of potential VOC emissions per year, well below a level of potential 

VOC emissions that would subject the operation to the new source review program based on 

VOC emissions. 

A. Applicability

An owner or operator who purchases 855 gallons or more of coatings and cleaning solvents in 

aggregate per rolling 12-month period for miscellaneous metal and plastics parts or pleasure craft 

coating operations must comply with amended section 22a-174-20(s) or section 22a-174-20(kk), 

respectively. Additionally, any owner or operator subject to section 22a-174-20(s) before 

January 1, 2012 must comply with either amended section 22a-174-20(s) or new section 22a174-20(kk), as appropriate. 

B. Exemptions and Exceptions

Proposed subsections (s) and (kk) both include exemptions recommended in the 2008 CTG, such 

as an exemption for coatings applied with a hand-held aerosol can; and an exemption for 

coatings applied in research and development, quality control or performance testing. Both 

subsections also include exemptions to delineate the interactions between the subsection and 

other requirements of the Connecticut air quality regulations. 

Some of the exemptions in subsection (s) address the needs of particular industries. For 

example, General Dynamics Electric Boat provided a demonstration that the shipbuilding 

national emissions standards for hazardous air pollutants (NESHAP) results in an equivalent 

level of control as the 2008 CTG, and so CTDEEP provided an exemption for shipbuilding and 

repair operations subject to and operating in compliance with the shipbuilding and repair 

NESHAP. Pratt & Whitney and Sikorsky requested an exemption for aerospace companies 

based on compliance with the aerospace NESHAP. However, Pratt & Whitney and Sikorsky 

were not able to demonstrate that the NESHAP was as protective of air quality as the 2008 CTG, 

so the request for this exemption was rejected. What CTDEEP and the aerospace companies 

were able to agree to as an alternative approach was the addition of a set coating VOC content 

limits developed from the aerospace CTG.3 

 

3 Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing 

and Rework Operations. EPA-453/R-97-004. December 1997.
4

Both subsection (s) and subsection (kk) include exemptions that may benefit any industry. For 

example, both subsections allow an owner to use 55-gallons in aggregate of non-compliant 

coatings in a 12-month rolling period. This allows for small but necessary quantities of certain 

coatings to be used without those alone triggering compliance measures. Subsection (s) also 

allows an owner to petition the commissioner to use more than 55-gallons of noncompliant 

coatings, with sufficient justification for such use. 

Other exemptions in subsection (s) were added in response to stakeholder input, such as an 

exemption for the use of coatings containing VOC at concentrations less than 1.0 percent by 

weight; and an exemption for the use of cleaning solvents containing VOC at concentrations less 

than 5.0 percent by weight. In response to a comment submitted at hearing, an exemption was 

added concerning coating of metal and plastic objects for maintenance of the facility. Touch up 

coating to fixtures and equipment used in the production process but which are not a product of 

the operation is not an activity subject to the requirements of subsection (s). 

C. Compliance Options

Sections 22a-174-20(s) and 22a-174-20(kk) provide three primary options for controlling VOC 

emissions: (1) VOC content limits for each coating category based on the use of low-VOC 

coatings and specified application methods to achieve good transfer efficiency; (2) equivalent 

VOC emission rate limits based on a combination of low-VOC coatings, specified application 

methods, and add-on controls; or (3) an overall VOC control efficiency of 90 percent for 

facilities that choose to use add-on controls instead of low-VOC coatings and specified 

application methods. Work place practices are specified to limit unnecessary loss of VOC to the 

atmosphere from materials and wastes handling, leaks and spills.

While allowed in the 2008 CTG, the proposal does not include a compliance option that allows

sources to limit the daily weighted average of the as-applied VOC content of all coatings in a 

single coating category used on a single coating unit. CTDEEP reserves the use of averaging 

only for sources that require an alternative compliance option through a consent order issued 

under RCSA section 22a-174-20(cc). 

An owner or operator may also choose to control VOC emissions under sections 22a-174-20(s) 

and 22a-174-20(kk) by limiting, by permit or order, VOC emissions from coating and related 

cleaning to 1,666 pounds or less in any calendar month. An owner or operator may request a new 

order or a revision to an existing order at any time. To ensure approval prior to the January 1, 

2013 compliance date, the request for a new order or a revision to an existing order should be 

submitted no later than August 1, 2012. After the compliance date, any miscellaneous metal and 

plastic parts coating at a facility that does not have an approved order or any coating activities

subject to the revised section 20(s) that are not covered under a current order or approved

revision must be conducted in compliance with subsection (s) or the facility will be in violation.

D. Record Keeping

Owners and operators of sources subject to either RCSA section 22a-174-20(s) or 22a-174-

20(kk) are required to maintain monthly records based on the quantity of coatings and cleaning 

solvents either purchased or actually used. Sources that do not meet the applicability thresholds 

of either subsection are required to maintain material purchase or actual usage records to verify 

that the regulations do not apply to them.
5

E. Compliance Date

The draft sections include a compliance date of June 1, 2012. Depending on the speed with 

which this proposal moves towards adoption, CTDEEP intends to adjust the compliance date to 

follow the adoption date of the proposal, with some months for CTDEEP to engage in outreach 

to regulated businesses and for those regulated businesses to change practices in response to the 

proposal. 

IV. Regulatory Approach

The process used to develop proposed subsections (s) and (kk) and significant issues addressed 

in the regulatory design process are set out in this section.

A. Process

CTDEEP developed subsections (s) and (kk) in an iterative drafting approach that included 

consultation with other divisions of CTDEEP, EPA, consultants and representative of regulated 

industries. 

Subsection (s) of RCSA section 22a-174-20 currently regulates miscellaneous metal parts 

coating. Initial drafts of the proposal included only a revised version of subsection (s), revised to 

address metal and plastic parts coating, based on the information in the CTG. The separation of 

pleasure craft coating occurred later in the process in response to informal comment. The first 

draft of subsection (s) was prepared in December 2008. Five more drafts were prepared in 2009 

based on internal review, and the draft, which included pleasure craft coating as a type of 

miscellaneous metal and plastic parts coating, was first provided to CTDEEP’s advisory 

committee, SIPRAC,4in February 2010. 

Meetings were held with a volunteer subcommittee of SIPRAC, which subcommittee included 

22 representatives of regulated industries, attorneys and environmental consultants. Staff from 

the Bureau of Air Management’s Engineering and Enforcement Sections also attended meetings. 

Meetings of the full subcommittee were held in February, March, April and October 2010. A 

separate meeting for representatives of aerospace manufacturing and repair facilities was held in 

November 2010. 

Consultations with and documentation from the American Coatings Association (ACA) resulted 

in two meetings, in June and July 2010, specific to pleasure craft coating. In addition to 

representatives from ACA and its member companies, representatives of the Connecticut Marine 

Trades Association, CTDEEP Boating Division and the Office of Long Island Sound Programs 

attended. 

CTDEEP is particularly grateful to Bob McConnell of EPA Region 1 who provided information 

and expertise throughout the drafting process. Responses to our questions often required 

research or interactions with EPA staff at Region 1 and Headquarters, yet Mr. McConnell 

responded to our numerous inquiries without delay. 

 

4

 SIPRAC is the State Implementation Plan Revision Advisory Committee, which meets monthly in Hartford, 

CT. More information is available on the CTDEEP website: 

http://www.ct.gov/dep/cwp/view.asp?a=2684&q=322192&depNav_GID=1619
6

B. Approach

A number of issues addressed during regulatory development are discussed here. 

Two Sets of Requirements. One of the most significant changes in the draft regulatory 

requirements was the separation of pleasure craft coating from miscellaneous metal and plastic 

parts coating. CTDEEP chose to separate surface coating requirements for pleasure craft from 

section 22a-174-20(s) and promulgate the pleasure craft requirements as new section 22a-174-

20(kk) because of the differences in the nature of the operations and the regulatory histories. 

Metal and plastic parts are typically coated on a coating line in a job shop setting, whereas 

pleasure craft are usually coated out-of-doors at a marina. Further, pleasure craft coating is 

concentrated during a few months each year, while job shops typically operate relatively 

constantly throughout the year. Historically, EPA and CTDEEP have had an established 

regulatory approach for metal parts coating, but not pleasure craft coating. EPA’s regulatory 

approach for pleasure craft in the 2008 CTG has no federal precedent, but was developed from 

California district requirements. 

EPA’s response5to the American Coatings Association (ACA) request for reconsideration of the 

2008 CTG was instrumental to CTDEEP’s decision to regulate the miscellaneous metal and 

plastic parts coating operations separate from pleasure craft coating operations. ACA had asked 

for EPA’s reconsideration of the emissions limits as not representing RACT for the pleasure craft 

coating industry. ACA also asked for alternative compliance options and additional coating 

categories. Although EPA denied the request for reconsideration, EPA’s response encouraged 

ACA to work with state agencies to adopt appropriate requirements and emphasized that state 

agencies are free to take approaches that differ from the CTG for the pleasure craft coating 

industry. CTDEEP understood the EPA request to provide sufficient leeway in implementation 

to allow for the development of specific requirements for pleasure craft coating and requirements 

that differ in some respects from those for parts coating. 

Once In, Always In. RCSA section 22a-174-20(s) determines the applicability of an operation 

based on daily emissions. Exceeding the threshold even once requires an operation to continue 

to operate under RCSA section 22a-174-20(s) in perpetuity. EPA refers to this approach as the

“once in, always in” RACT policy. CTDEEP is devising the applicability for new subsection (s) 

using a longer averaging time, a 12-month rolling period, as allowed by the CTG. Some owners 

of operations that typically are well below the new applicability on the 12-month basis were 

hopeful that the operation would no longer be subject to RCSA section 22a-174-20(s), given the 

promulgation of new emissions standards and other emissions control requirements. However, 

staff at EPA Region 1 confirmed that EPA remains dedicated to the “once in, always in” policy, 

even under a significantly altered regulation. Miscellaneous metal parts sources that are now 

subject to Section 20(s) must remain subject to the new version of Section 20(s), despite the 

broader applicability and new requirements.

Applicability. While CTDEEP historically has set the applicability for CTG-based requirements 

using a daily averaging period, CTDEEP finds that a 12-month rolling averaging period, which is 

acceptable under the CTG, is more appropriate to our current air quality needs and business 

environment. The longer averaging period means that only operations that typically operate

 

5

 Stephen D. Paige. Control Technique Guidelines for Miscellaneous Metal and Plastic Part Coatings – Industry 

Request for Reconsideration. June 1, 2010. 
7

above the threshold will be regulated. The daily averaging period resulted in an operation that 

had a very high level of operation for only a single day being subject to regulation, even if 

operations on a typical day were well below the applicability threshold. In combination with the 

“once in, always in” policy, a source would remain regulated for its life span based on one day of 

operation. 

In combination with the change in the averaging period for the applicability, CTDEEP also 

changed the metric from actual VOC emissions to purchases of VOC-containing coatings and 

solvents. Materials purchased are commonly tracked, and purchase records are commonly 

maintained, even at very small operations, while determinations of actual emissions are difficult 

for less environmentally sophisticated business owners. The use of a 12-month rolling period 

and materials purchased to determine applicability are proposed for both subsections (s) and 

(kk). 

Some purchased materials are not included in the total to determine applicability, namely the 

coatings and cleaning solvents that are listed as exempt. 

Concerning applicability determinations and pleasure craft coating, the use of a 12-month period 

is particularly important because pleasure craft coating is typically concentrated during a few 

months of the year. Also, very little coating activity occurs during the ozone season, since, in 

Connecticut, the ozone season and boating season are coincident. 

Section 22a-174-20(kk) applies to commercial pleasure craft coating activities, not to coating of 

a single boat by the boat owner or by the boat owner’s uncompensated agent, regardless of where 

the boat is located when coated. Marina and boat yard operators are not required to track the 

coating use and practices of storage customers when the customers perform their own coating. 

Coatings and cleaning solvents purchased for noncommercial application by marina customers 

are not included in the total gallons of coatings and solvents used by a marina owner or operator 

to determine the applicability of section 22a-174-20(kk).

Related Cleaning. The CTG recommends that a state should regulate coating and related 

cleaning. Discussions with our stakeholders made it evident that a definition of “related 

cleaning” was necessary to understand what to include for both the limitations to 1,666 pounds 

of VOC per month and applicability determinations. Related cleaning includes booth cleaning, 

cleaning of parts at the point of coating, cleaning of equipment to prevent cross-contamination 

and cleaning of uncured coatings from tools and work areas. Related cleaning does not include 

janitorial cleaning, routine maintenance cleaning or cleaning of parts subject to a distinct set of 

requirements in RCSA section 22a-174-20 or another regulation. 

CTDEEP added a definition of “related cleaning” to subsection (s) and subsection (kk) to make 

its intent clear. For example, the definition added to subsection (s) is as follows: 

“Related cleaning” means the removal of uncured coatings, coating residue and 

contaminants from:

(i) miscellaneous metal and plastic parts prior to the application of coatings;

(ii) miscellaneous metal and plastic parts between coating applications; or
8

(iii) transfer lines, storage tanks, spray booths, and coating application equipment;

Regulatory Interactions. The requirements of RCSA section 22a-174-20 apply regardless of 

obligations on the owner to obtain a permit. An owner subject to the requirements of RCSA 

section 22a-174-20 should also verify the applicability of RCSA section 22a-174-3a, the new 

source review program regulation, to the operation, particularly for a new or modified operation. 

Similarly, RCSA section 22a-174-20 addresses VOC emissions, but emissions of other pollutants 

from the coating operation may be subject to other state requirements. A good example of such a 

situation is the possibility for the requirements of RCSA section 22a-174-18 to apply to pleasure 

craft coating or sandblasting. If an owner sandblasts a pleasure craft or applies coatings by spray 

application, the particulate matter and visible emissions standards of RCSA section 22a-174-18 

apply. 

The possibility of overlapping applicability requirements between subsection (s) and other 

subsections in RCSA section 22a-174-20 is addressed in a number of exemptions. The result of 

the exemptions in proposed subsection (s) and exemptions elsewhere in RCSA section 22a-174-

20 is that any operation or activity is subject to a single set of requirements. 

Two other subsections deserve mention in terms of how they interact with solvent cleaning 

conducted in relation to metal and plastic parts coating. EPA intends that general cleaning 

related to miscellaneous metal and plastic parts coating should only be subject to the metal and 

plastic parts coating CTG-based requirements and should be exempt from requirements for 

industrial cleaning set out in a separate CTG.6 RCSA section 22a-174-20(ii) includes an 

exemption for cleaning conducted under RCSA section 22a-174-20(s). No similar exemption is 

included in RCSA section 22a-174-20(jj), which regulates spray gun cleaning. As RCSA section 

22a-174-20(s) does not specifically regulate spray gun cleaning, required compliance with 

subsection (jj) is appropriate. However, if emissions from spray gun cleaning are controlled as 

required under the options provided in subsection (jj), those emissions would not be included in 

the applicability determination for subsection (s). 

Concerning federal regulations that may apply to pleasure craft coating, ACA suggested that 

EPA would soon be proposing a NESHAP for pleasure craft coating. EPA has advised us that no 

such NESHAP is imminent. The NESHAP for paint stripping and miscellaneous surface coating 

operations at area sources under 40 CFR 63 subpart HHHHHH has limited applicability to 

pleasure craft coating sources. Paint stripping activities that are subject to the NESHAP are not 

regulated under the proposal. Sources in Connecticut typically coat pleasure craft using hand 

application methods, not spray application which is regulated by subpart HHHHHH, so the 

NESHAP is likely of little consequence to sources subject to RCSA section 22a-174-20(kk). 

Military specification coatings. Regulated industry representatives commented that military 

specification coating category is unnecessary and should be eliminated, since each coating that 

might meet the definition of military specification coating also meets a definition for a functional 

coating category. The functional coating category VOC content limits are generally the same as 

the military specification coating limits, although a few are higher and a few are lower. Given 

that the quantity of military specification coating used in the state is small, CTDEEP concluded 

 

6 Control Techniques Guidelines: Industrial Cleaning Solvents. September 2006. EPA 453/R-06-001. 
9

that maintaining the separate military specification category would not provide a significant air 

quality benefit and would hinder compliance determinations by both regulated stakeholders and 

CTDEEP staff. Therefore, the Department deleted the military specification category. 

VOC Content Limits for Pleasure Craft Coatings. The pleasure craft coating VOC content 

limits for Extreme High Gloss Topcoat, Other Substrate Antifoulant Coating, and Antifouling 

Sealer/Tie Coating are less stringent than recommended in the CTG. 

CTDEEP chose to reduce the VOC content limits on recommendation and information supplied 

by the American Coatings Association (ACA) during the preparation of the proposal. ACA 

explained that EPA did not fully consider pleasure craft coating throughout the CTG 

development process and did not have key information concerning the VOC content limits for 

the three coating categories noted. ACA also commented that the experience of the South Coast 

Air Quality Management District (SCAQMD) demonstrates that the CTG limits, which were 

taken directly from SCAQMD Rule 1106.1, are not practical. For example, the “other substrate 

antifoulant coating” category was recommended for a VOC content limit of 330g/L, even though 

the Shipbuilding and Repair NESHAP and SCAQMD Marine Rule 1106 require a VOC content 

limit of 400 g/L for antifoulant coatings. Also, antifoulant coatings with a VOC content below 

400 g/L require more applications than the higher VOC content coatings, potentially resulting in 

more environmental detriment overall given the nature of antifouling coatings. 

For finish primer/surface, CTDEEP provides an interim VOC content limit of 600 g/L before 

moving to a 420 g/L standard in 2016, in recognition that commercially available coatings in this 

category do not yet deliver the quality of finish expected, but are rapidly improving. 

CTDEEP also added a new category for pleasure craft coating, antifouling sealer/tie coat, with a 

VOC content limit of 420g/L. 

V. Connecticut Source Inventory

Because many of the sources regulated by this proposal are below Connecticut’s permitting 

thresholds, there is a significant degree of uncertainty in determining the number of sources 

impacted in either the parts coating or pleasure craft coating categories. 

A. Miscellaneous Metal and Plastic Parts Category

The miscellaneous metal and plastic parts source category includes metal and plastic components 

of small and large farm machinery, commercial and industrial machinery and equipment, 

automotive or transportation equipment, interior or exterior automotive parts, construction 

equipment, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles,

recreational boats, extruded aluminum structural components, railroad cars, lawn and garden 

equipment, business machines, laboratory and medical equipment, electronic equipment, steel 

drums, metal pipes and small appliances. Because this source category includes such a diverse 

group of facilities, estimating the number of affected facilities in the state with any certainty is 

difficult. 

Although EPA in the 2008 CTG provides a list of North American Industry Classification 

System (NAICS) codes that includes all potentially regulated industrial categories, the collection 

of sources in the identified categories includes operations that do not conduct regulated coating. 

Obtaining an accurate estimate of the number of regulated facilities using NAICS codes is also 
10

confounded because a single source may be counted multiple times if the source engages in 

activities in several NAICS categories. 

CTDEEP used EPA’s list of NAICS codes for potentially regulated sources to search the U.S. 

Census Bureau’s 2007 economic data and identified 361 small businesses in Connecticut as 

potentially impacted by the proposed amendments. By comparison, EPA estimates that the CTG 

requirements apply to 1,296 facilities nationwide. CTDEEP’s estimate of 361 potentially 

impacted small businesses is a large proportion of EPA’s estimate, suggesting that one or both 

estimates are not accurate. The 2007 Connecticut Emission Inventory includes 125 potentially 

affected facilities. Some of those facilities, however, are minor sources with emissions below 

the applicability threshold of RCSA section 22a-174-20(s), as revised based on the 2008 CTG. 

B. Pleasure Craft Category

The number of boat building and repair facilities in Connecticut that may be subject to the 

requirements is also difficult to estimate. According to the U.S. Census Bureau’s 2007 economic 

data, there are only 10 businesses in Connecticut in the boat building category and another eight 

businesses in the shipbuilding and repair category. CTDEEP believes that this is a significant 

underestimate of the number affected sources. The Connecticut Marine Trade Association, for 

example, lists about 240 entities in Connecticut that appear to be marinas, boat yards or boat 

dealers, some of which conduct boat coating and repair as a secondary part of their business. 

Any such facility that engages in commercial boat coating or re-coating would be subject to the 

requirements of proposed RCSA section 22a-174-20(kk). 

VI. Economic and Small Business Impact

The anticipated financial impact of the proposal on businesses ranges from a minimal savings to 

moderate costs. EPA estimates the costs of compliance for miscellaneous metal and plastic parts 

coating operations to be $10,500 per facility. The actual cost of compliance at many facilities is, 

however, expected to be lower. EPA did not account for the anticipated net savings potential as a 

result of the mandated work practices and application methods that reduce coating and solvent 

usage by decreasing waste and evaporation, thereby reducing material purchase costs. 

Furthermore, EPA’s cost estimate was made without regard for facility size or type of operation 

and has its basis in the compliance costs for a rule designed to control hazardous air emissions, 

not VOCs. California and several other states currently have similar coating VOC content limits 

requirements in place. Compliant metal and plastic parts coatings are reported to be available at 

a cost that is not significantly greater than the cost of traditional, high-VOC coatings. However, 

information provided by pleasure craft coating suppliers suggests that an increase of about 40 

percent can be expected. 

The proposal also includes provisions that reduce the administrative burden on businesses. For 

example, applicability is determined based on coatings and solvents purchased. Since purchases 

are typically tracked and recorded, even in the smallest business, the applicability determination 

is easily made. Reporting is only required on request, thereby reducing the administrative costs. 

For pleasure craft coating operations, the use of a 12-month rolling average of materials 

purchased to determine applicability, plus the availability of an alternative compliance option for 

operations with actual emissions of less than 1666 pounds of VOC in any calendar month, 

provides coating operation with several compliance options. 
11

Exemptions from coating VOC limits, application methods, and work-practice requirements are 

included in both proposed subsections to address special circumstances and reduce the regulatory 

burden on small businesses. Further, several compliance options are provided so that business 

owners and operators have the flexibility to choose the VOC control method most suitable for 

their operating needs.

VII. Air Quality Impact

The VOC emissions from miscellaneous metal product and plastic part and pleasure craft surface 

coating result from the evaporation of the volatile components of the coatings and cleaning 

materials used in these operations. Essentially all the VOCs contained in a coating evaporate. 

Therefore, lowering the VOC content of coatings and improving coating efficiency directly 

lowers VOC emissions.

EPA estimates that decreasing the allowable VOC content for coatings and cleaning materials 

will reduce VOC emissions from miscellaneous metal and plastic part (including pleasure craft) 

coatings by about 35 percent. In analyzing potential reductions, EPA assumed that all facilities 

will choose to utilize the low-VOC coating materials option because low-VOC coating materials 

are already widely available at a cost that is not significantly greater than the cost of coating 

materials with higher VOC contents. Also, the use of add-on controls to reduce emissions from 

typical spray coating operations is a more costly option.

The 125 potentially affected facilities included in the 2007 Connecticut Emission Inventory had 

total reported annual VOC emissions of approximately 640 tons. Many of the small sources are 

not required to report their emissions on a regular basis, so the inventory may not accurately 

quantify current emissions. Additionally, many of these small sources are not subject to these 

amendments because their emissions are below the applicability threshold. Assuming all 

emissions recorded in the 2007 inventory are subject to the proposed regulations, and using 

EPA’s estimate of a 35 percent reduction in emissions, a 220 ton per year reduction in VOC 

emissions would result from implementing the proposed requirements. Alternatively, if fewer

emissions are subject to the proposal, and again assuming a 35% reduction, proportionally lower 

emissions reductions would be obtained as shown in the table below:

% of 2007 

reported 

emissions subject 

to rule 

emissions 

reductions 

(tons/year)

100% 220

90% 200

80% 180

70% 160

60% 130

50% 110