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) 509~6175R-39 Rev. 02/20i2 

### Page 1 of 36

State of Commcticut



## of

NAME OF AGENCY

Department 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

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

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

(i) Large farm machinery suc h 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,

va cuum 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, trans formers, 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 indu stries), 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 manufac turing 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 can s,

(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 refi nishing,

(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

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(3) Emission standards. No owner or operator of a facility engaged in the surfa ce 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 exemp t 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 C FR 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 w ater 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 or ganic 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 w hich 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 compou nd 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 app ly 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 e missions 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

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(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 subsecti on 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 s ubs ection, the following defini tions 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
compone nts 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 th e subsequently applied material ;

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

c orrosion and increase adhes ive 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

co mpleted unit, with the exception of electronic components, of any aircraft including but not limited to airplanes, helicopters, missil es, rockets and space vehicles;

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

“ 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 no rmal operations or installation;Page 5 of 36

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“ Antiqu e 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 cap acity for which it was designed;

“Appurtenance” means any accessory to a stationary structure, including but not limited to: bathroom and k itchen 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 d ownspouts; stairways; fixed ladders; catwalks; fire
escapes and window screens ;

“ As applied” m eans 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 wat er 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 subs trate 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 adja cent to such a bearing to facilitate bearing function or to protect base material from excessive w ear. “Bearing coating ” doe s not include a material that can also be classified as a dry lubricative mat erial or a solid film lubricant;

“Bonding maskant ” means a temporary coating used to protect selected areas of aerospace parts from strong acid or alk aline solutions during processing for bonding ;
“Business machine” means a device that uses electronic or mechanical methods to process information, perform calculat ions, 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 eq uipment 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;

“Ca ulking and smoothing compound ” me ans a semi

- solid material that is appl ied by hand and used to smooth exterior vehicle surfaces or fill cavities such as bolt hole accesses. “ C aulking 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 deco ntaminants 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 ar e defined as specialty coatings or mas kants used with either a Type I or II etchant plus a bonding maskant, criti cal use and line sealer maskant or seal coat maskant ;Page 6 of 36

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“Cleaning solvent” means any VOC

- containing liquid, including a liquid impregnated wipe or towelette, used in cleaning;

“Cle ar coating” means a colorless coating that contains binders but no pigment an d 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 aestheti c, pro tective 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 dryin g 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 app l ication 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
purpos e of extended corrosion p rotection and enhanced adhesion;

“ Commercial interior adhesive ” means a material used in the bonding of pass enger 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 c orrosion 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 c an be expected to c ome 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;

“ C orrosion 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 c oating con taining 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 pr ocessing of magnesium, titanium or high A 8 strength steel, high

- precision aluminu m chemical milling of deep cuts and aluminum che mical milling of complex shapes, and includes m aterials used for repairs or to brid ge gaps left by scribing operations ;

“ Cryogenic flexible primer ” means a primer designed to provide co rrosion resistance, flexibility and adhesion of subsequent coating systems when exposed to loads up to and surpassing the yield point of the substrate a t 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

- e ntry and prevent i ce formation;Page 7 of 36

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“ Cyanoacrylate adhesive ” means a fast

- setting, single component adhesive that cures a t room temperature and contains methyl, ethyl, methoxymethyl or other functional groupings of cyanoacrylate ;
“Dip coating” means a method of applying a coa ting 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 non

cross linked or resin

- bound materi als that act as a dry lubricant;

“Electric dissipating coating” means a coating that rapidly dissipates a high

- voltage electric charge;

“Electric

- insulating and thermal

- cond ucting 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 c oating 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 int eract, 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) p rotec tion 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 co ating ” or “EMI coating” means a coating applied to space vehic les, missiles, aircraft radomes and helicopter blades to disperse static energy or redu ce electromagnetic interference;

“Electrostatic preparation c oating” means a coating applied to a plastic part solely to provide conductivity for the subsequent ap plication 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 pr imarily to commercial aircraft or commercial air craft adapted for military use that withstand s immersion in phosphate

- ester hydraulic fluid (Skydrol 500b or equivalent) at the elevated tempe rature of 150°F for 1,000 hours;

“EMI/RFI shield coating” means a coating t hat 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 fin ish ;
“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

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“Extreme high

- gloss coating” means a coating that, when tested by American Society for Testing Material Test Me thod 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 fo llowing conditions:

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

, chemical mixtures or solution,

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

(C) Repeated heavy abrasion, including mechanical wea r and repeated scrubbing with industrial grade solven ts, cleaners or scouring agents;

“ Fire

- resistant interior coating ” means , for civilian aircraft, fire

- resistant interior coatings used on passenger cabin interior pa rts that are subject to Federal Avia tion 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 requirem ents 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 ;

“ F light 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 markin g during flight test evaluation;

“Flow coating” means a non

- ato mized 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 pu rpose 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 compone nts exposed to fuel ;

“ Fuel tank coating ” means a coating applied to fuel tank components for the purpose of corrosion or bacterial growth i nhibition and to assure sealant adhesion in e xtreme environmental conditions;

“General” means a coating category for a coating that do es not meet any oth er 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, main tenance, 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

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“High

- performance architectural coating” means a coating used to protect architectural subsections and which meets the requirements of the Architectural Aluminum Manufa cturer 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 Requiremen ts and Test Procedures for Superior Performing Organic Coatings

on Aluminum Extrusions and Panels);

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

“HVLP spray application” means to apply a coating u sing 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
pa ckaging or other product literature;

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

mec hanical or environmental damage;

“ Intermediate release coating ” means a thin coating applied beneath topcoats to assist in removing the topcoat in depa inting operations and to allow the use of le ss hazardous depainting methods;

“ Lacquer ” means a clear or pigmented coating formulated with a nitrocellulose or synthetic resin to dry by evaporati on without a chemical reaction and that is reso luble 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 thr ough 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, whic h 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,
trea tment or pre vention 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 app earance or added protection;

“Metallic coating” means a coating that conta in s more than five grams of metal particle s p er 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 met al 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 o r exterior automotive parts, construction equipment, motor vehicle accessories,Page 10 of 36

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bicycles and sporting goods, toys, recreational vehicles, extruded aluminum structural components, railroad cars, lawn and garden equipment, business machines, laboratory and m edical equipment, electronic equi pment, steel drums, metal pipes and small appliances ;

“Mold

- seal coating” means the initial coating ap plied to a new mold or a repaired mold to provide a smooth surface that, when coated with a mold release coating, preven ts products from sticking to the mold;

“ Mold release ” means a coating applied to a mold surface to prevent the molded piece from sticki ng to the mold as it is removed;

“ Motor v ehicle” means any self

- propelled vehicle, including, but not limited to, car s, 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 re sistance;

“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 pu rpose 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 sea ling material includes room temperature vulcanization (RTV) seal material;

“ Motor vehicle lubricating wax/compound ” means a protective lubricating material app lied to vehicle hubs and hinges;

“ Motor vehicle sealer ” means a high viscosity material genera lly, 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 fi ll 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 coatin g ” means a coating applied to the trunk inte rior 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 coat ing 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 applicat ion 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 othe r specialty adhesive categories;

“One

- component coating” means a coat ing that is ready for application as packaged for sale, except for the addition of a thinner to reduce the viscosity;Page 11 of 36

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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 th e 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 c oating ” means coatings or inks used to make permanent or temporary identifying marking s 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 pi eces may be so lid, porous, flexible or rigid . “Plastic part ” do es not include a part made of f iberglass 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 appur tenances or structures and that are detached from the structure when coated in a shop environment ;
“Pretreatment coating” means a coati ng, containing at least 0.5 percent acid by weight, applied directly to a metal or composite surface to provide surface etching, corrosion resistance, a dhesion and ease of stripping;

“Primer” means a coating applied to prevent corrosion, provide protect ion or provide a surface for adhesion of subsequent coatings;

“ Radome ” means the nonmetallic protective housing for electromagnetic transmitters and receivers such as radar or el ectronic countermeasure s ;

“ 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 caus ed by rain impact during flight;

“Related cleaning” means t he removal of un cured coatings, coating residue and contaminants from:

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

(B ) M iscellaneous metal and plastic par ts between coating applications, or

(C ) T ransfer lin es, storag e tanks, spray booths an d coating application equipment;

“Repair coating” means a coating used to recoat portions of a product that has sustained mechanical damage to the coating follo wing normal painting operations;

“Resin” means any of numerous physi cally similar polymerized synthetics or chemically modified natural materials including thermoplastic materials such as polyvinyl, polystyrene and polyethylene and thermosetting materi als such as polyesters, epoxies and silicone s;Page 12 of 36

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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 appli cations 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 oppos itely rotating rollers;

“ Rubber

- based adhesive ” means a quick

- setting contact cement that provide s a strong, yet flexible bond between two substrates that may be of dissimilar materials;

“Safety

- indicating coating” means a coating that changes in a physi cal 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 th e intrusion of water, fuel, air or other liquids or solids from certain areas of ae rospace vehicles or components;

“ Seal coat maskant ” means an overcoat applied over a maskant to improve abrasion and chemical resistan ce during production operations;

“Self

- priming topcoat” means one or more layers of identi cal coating formulation of a topcoat that is applied directly to an uncoated aerospace vehi cle or component for corrosion prevention, environmental protection or functional fluid resistance;

“Shock

- free coating” means a coating applied to electrical components to protec t the user from electric shock and that provides for low capacitance and hig h resistance and resists b reaking 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 atmosph eric fri ction 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

- absorben t coating” means a coating th a t has as its primary purp ose th e 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

ear th's atmosphere , including, but not limited to, integral equipment such as models, mock

- ups,Page 13 of 36

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prototypes, molds , jigs, tooling, hardware jackets and test coupons, including auxiliary equipment associated with test, tran sport and storage, which through contamination can compromis e 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 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 o r enhanced corrosion protection;

“Specialized function coating” means a coating that is limited in application, ch aracterized by low v olume usage and is not able to be categorized as any other coating in Table 20(s)

- 6 a ;
“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 he at 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 bond ing in the proximity of engines;

“ Temporary protective coating ” means a coating applied to provide scratch or corrosion protectio n during manufacturing, storage or transportation. “Temporary protective coating ” do es not include any coating that protects against str ong acid or alkaline solutions;

“Texture coat” means a coating that is applied to a plastic part which, in its finished form, consists of discrete ra ised spots of the coating;

“Textured finish” means a rough surface produced by spraying and splattering large drops of coating onto a previously applied coati ng ;

“ Thermal control coating ” means a coating formulated with specific thermal conductive or rad iative properties to permit tempe rature control of the substrate;

“Top coat” 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 a fter the m ain 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 soli ds 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

- me talizing process or the overcoat applied directly to the metal film after a vacuum

metalizing process ;
“Vacuum metalizing process” means the process of evaporating metals inside a vacuum chamber and depositing them on a substrate to achieve a uniform met alized layer;Page 14 of 36

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“ Wet fastener installation coating ” means a primer or sealant applied by dipping, brushing or daubing to fasteners that are instal led before the coating is cured; and

“ Wing coating ” means a corrosion

- resistant topcoat that withstand s the fl exing 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 coati ngs 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

s hall 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 ) Exce pt 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 o wner or operator control s emissions of VOCs in accordance with subpar agraph (A), (B), (C) or (D) of this subdivision. If more than one emis sion 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 V OC 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)

- 6 a or 20(s)

- 6 b ;

(B) For a coating unit, u se a combination of low

- VOC coatings and add

- on air po llution control equipment to achieve a VOC emission rate no greater th an 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 wi th an overall contro l efficiency of at least 90%; orPage 15 of 36

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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 emission s 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. Exce pt as provided in subdivision (7 ) of this subsection , a n 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 applicati on;

(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 us ing 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 , d iluent 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;Page 16 of 36

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(C) Absorbent applicators, suc h 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

(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, a n owner or operator complying with this subsection by op erating under a valid permit or order issued pursuant to subsection (cc)(2) or (cc)(3) of this section shall continue to operate according to th e terms of such permit or order.

(7) Exemptions and exceptions.

(A ) T he requirements of this subsection shall not apply to any of the following activities, and the VOC emissions result ing from the following activities shall not be included in determinations pursuant to subdivisi on s (2) and (7 )(G ) of this subsection:

(i) Coating and cleaning subject to one of the following subsections of this sec tion: ( l ) through (r) and (hh) throu gh (kk),

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

, (iii) Coating and associated surface preparation and cleanup subject to section 22a

174

- 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 app lied 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,

( i x ) Adhesive, sealant, adhesive primer or sealant primer regulated by section 22 a

174

- 44 of the Regulations of Connecticut State Age ncies,

(x ) Quality control or inspect ion 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 requiremen ts of sub divisions (3) and (4 ) of this subsection shall not apply to the application of any of the following coatings to metal parts:Page 17 of 36

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(i) Stencil coating,

(ii) Safety

- indicating coating,

(iii) Solid

- film lubricant,

(iv) Electric

- insulating and thermal

- conducting c oating,

(v) Magnetic data storage disk coating,

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

(vii) Powder coating.

(C ) The requirements of s ubdivision (3 ) of this subsection shall not apply to the application of any of the following c oatings 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 millimeter s 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 pe r year, or

(viii) Powder coating.

(D ) The requirements of s ubdivision (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,

(i i ) Gloss reducer,

(iii ) Texture coat,

(iv ) Adhesion bonding primer,

(v ) Electrostatic preparation coating,

(vi ) Resist coating,

(vii ) Stencil coating, orPage 18 of 36

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(viii ) Powder coating.

(E ) The requirements of subdivisions (3) and (4 ) of this subsection sha ll 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 accorda nce with 32 CFR 2001.

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

(i) Application of t ouc h

- up and repair coating to metal parts,

(ii) Application of t extured finish to metal parts,

(iii) Ap plication of p owder coating to:

(I) P lastic parts,

(II) Automotive

- transportation plastic parts, or

(III) B usiness machine plastic parts,

(iv ) Airbrush application of coating to metal or plastic parts using no more than five gallons of coating per y ear,

(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)

- 6 a of this subsection.

(G ) An owner or operator with total potential VOC emissions from all mis cellaneous 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 subsect ion, provided that the owner or operator ope rates 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 coating s that exceed the VOC content limits or emiss ion 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 req uirements of this subsection, including, at a minimum, the following information for each calendar month:Page 19 of 36

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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 calcul ations,

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

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

(I) Purchased, or

(II) U sed,

(v) A Material Safety Data Sheet, Environmental Data Sheet, Certified Product Data Sh eet, 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 an d 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 reques t, 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)

- 6 b apply to th e volume of coating as applied , dete rmined 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 = vo lume 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 prope rties 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 thePage 20 of 36

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satisfaction of the commis sioner and the Administrator that the manufacturer’s formulation data are correct

.
(D ) For red, yellow or black au tomotive 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 inform ation 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 part s 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 part s coating at the premises in the monthly limit of 1,666 po unds 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

coat ing Gener al one

- c omponent 340 2.8 280 2.3 General multi

- c omponent 340 2.8 280 2.3 Camouflage 420 3.5 420 3.5

Electric

- insulating v arnish 420 3.5 420 3.5 Etching f iller 420 3.5 420 3.5 Extreme high

- g loss 420 3.5 360 3.0 Extrem e p erform ance 420 3.5 360 3.0 Heat

- r esistant 420 3.5 360 3.0 High performance

a rchitectural 740 6.2 740 6.2

High t emperature 420 3.5 420 3.5 Metallic 420 3.5 420 3.5 Mold

- s eal 420 3.5 420 3.5 Pan b acking 420 3.5 420 3.5Page 21 of 36

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Prefabricated archite ctural multi

- c omponent 420 3.5 280 2.3

Prefabricated architectural

one

- c omponent 420 3.5 280 2.3

Pretreatment c oating 420 3.5 420 3.5 Repair and touch

- u p 420 3.5 360 3.0 Silicone r elease 420 3.5 420 3.5 Solar

- a bsorbent 420 3.5 360 3.0 Va cuum

- m etalizing 420 3.5 420 3.5 Drum coating, new, e xterior 340 2.8 340 2.8 Drum coating, new, i nterior 420 3.5 420 3.5 Drum c oating, reconditioned,

e xterior 420 3.5 420 3.5

Drum coating, reconditioned, i nterior 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

- c omponent 280 2.3 General multi

- c omponent 420 3.5 Electric dissipating coatings and shock

- free

c oating 800 6.7

Extreme performance m ulti

- component 420 3.5 Metallic 420 3.5 Mold

- s eal 760 6.3 Multi

- colored c oating 680 5.7 Optical c oating 800 6.7 Vacuum

- m etalizing 800 6.7

Table 20(s)

- 3 Automotive

- Transportation Plastic Parts Coating VOC Content Limits Coating Category g VOC/l iter coating lbs VOC/gal coating I. High b ake coatings

– interior and exterior p arts Flexible p rimer 540 4.5 Non

- flexible p rimer 420 3.5 Base c oat 520 4.3 Clear c oat 480 4.0 Non

- base coat/clear coat 520 4.3 II. Low bake/air dried coatings

– exte rior p arts 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
p arts 600 5.0

IV. Touchup and repair c oating 620 5.2Page 22 of 36

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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)

- 6 a Aerospace Specialty Coating VOC Content Limits Coating type g VOC/liter coating Ablative c oating 600 Adhesion p romoter 890 Adhesive bonding p rimers: Cured at 250°F or below 850 Cured above 250°F 1030 Adhesives: Commercial interior a dhesive 760 Cyanoacrylate a dhesive 1,020 Fuel tank a dhesive 620 Nonstructural a dhesive 360 Rocket mot or bonding a dhesive 890 Rubber

- based a dhesive 850 Structural autoclavable a dhesive 60 Structural nonautoclavable a dhesive 850 Aerospace high

- temperature c oating 850 Antichafe c oating 660 Bearing c oating 620 Caulking and smoothing c ompounds 850 Chemical agent

- resistant c oating 550 Clear c oating 720Page 23 of 36

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Commercial exterior aerodynamic structure p rimer 650 Compatible substrate p rimer 780 Corrosion prevention c ompound 710 Cryogenic flexible p rimer 645 Cryoprotective c oating 600 Dry lubri cative m aterial 880 Electric or radiation

- effect c oating 800 Electrostatic discharge and electromagnetic interference (EMI)

c oating 800

Elevated

- temperature Skydrol

- resistant c ommer cial p rimer 740 Epoxy polyamide t opcoat 660 Fire

- resistant interior c oating 800 Flexible p rimer 640 Flight

- test c oatings: Missile or single use a ircraft 420 All o ther 840 Fuel

- tank c oating 720 Insulation c overing 740 Intermediate release c oating 750 Lacquer 830 Maskants: Bonding m askant 1,230 Critical use a nd line sealer m askant 1,020 Seal coat m askant 1,230 Metallized epoxy c oating 740 Mold r elease 780 Optical anti

- reflective c oating 750 Part marking c oating 850 Pretreatment c oating 780 Rain erosion

- resistant c oating 850 Rocket motor nozzle c oati ng 660 Scale i nhibitor 880 Screen print i nk 840 Sealants: Extrudable/rollable/brushable s ealant 280 Sprayable s ealant 600 Silicone insulation m aterial 850 Solid film l ubricant 880 Specialized function c oating 890 Temporary protective c oating 320 Thermal control c oating 800 Wet fastener installation c oating 675 Wing c oating 850Page 24 of 36

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Tabl e 20(s)

- 6 b 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 facil ities 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

s olids General one

- c omponent 540 4.52 400 3.35 General multi

- c omponent 540 4.52 400 3.35 Camouflage 800 6.67 800 6.67 Electric

- insulating v arnish 800 6.67 800 6.67 Etching f iller 800 6.67 800 6.67 Extreme high

- g loss 800 6.67 610 5.06
Ex treme p erforma nce 800 6.67 610 5.06
Heat

- r esistant 800 6.67 610 5.06 High performance a rchitectural 4560 38 4560 38 High t emperature 800 6.67 800 6.67 Metallic 800 6.67 800 6.67 Mold

- s eal 800 6.67 800 6.67 Pan b acking 800 6.67 800 6.67
Prefabricated architectural multi

c omponent 800 6.67 400 3.35
Prefabricated architectural one

c omponent 800 6.67 400 3.35
Pretreatment c oating 800 6.67 800 6.67 Silicone r elease 800 6.67 800 6.67 So lar

- a bsorbent 800 6.67 610 5.06
Vacuum

- m etalizing 800 6.67 800 6.67
Drum coat ing, new, e xterior 540 4.52 540 4.52 Drum coating, new, i nterior 800 6.67 800 6.67 Drum coating, reconditioned, e xterior 800 6.67 800 6.67 Drum coating, r econdition ed, i nterior 1170 9.78 1170 9.78Page 25 of 36

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- 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

- c omponent 400 3.35 General multi

- c omponent 800 6.67
Electri c dissipating coatings and shock

- free

c oatings 8960 74.7

Extreme p erformance multi

- component 800 6.67
Met allic 800 6.67 Mold

- s eal 5240 43.7 Multi

- colored c oatings 3040 25.3 Optical c oatings 8960 74.7
Vacuum

- m etalizing 8960 74.7

Table 20(s)

- 9 Automotive

- Transportation Plastic Parts Coating VOC Emission Rate Limits Coating Category g VOC/liter sol ids lbs VOC/gal solids I. High bake c o atings

– interior and exterior p arts Flexible p rimer 1 39 0 11.58
Non

- flexible p rimer 800 6.67
Base coat 1240 10.34 Clear c oat 1050 8.76
Non

- base coat/clear coat 1240 10.34
II. Low bake/air dried c oatings

– e xterior p arts Primer 1660 13.8
Base coat 1870 15.59 Clearcoat 1390 11.58
Non

- base coat/clearcoat 1870 15.59

III. Low b ake /air dried coatings

– interior p arts 1870 15.59
IV. Touch

- up and repair c oating 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 57 0 4.80 II. Topcoat 570 4.80
III. Texture coat 570 4.80 IV. Fog coat 380 3.14 V. Touchup and repair 570 4.80Page 26 of 36

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- 39 Rev. 02/2012

Sec. 2. Subdivisi on (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 su bsections (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 wei ght;

(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 alt er n ative emission reduction plan instead of compliance with the [ “ ] emissions limitation [ ” ] p rescribed in any one of subsections (m) through (v)

, inclusive

, [ and ] (ee)

o r (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) t o (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

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- 39 Rev. 02/2012

Sec. 4. Section 22a

- 174

- 20(ii)(3)(A) of the Regulations o f Connecticut State Agen cies 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
op eration in accordance with an order or a permit issued pursuant to sectio ns 22a

- 174

- 32(e) and 22a

- 1 74

- 20(cc) of the Regulations of Connecticut State Agencies,

(iii) To perform general solvent cleaning in accordance w ith an order issued pursuant to secti on 22a

- 174

- 20(ee) of the Regulations of the Connecticut State Agencies,

(iv) At any aerospace manufacturing and rework faci lity, provided that cleaning solvent is used in accordance with the requirements of 40 CFR 63.744, inclusive of exemptions,

(v) A s surface preparation or cleanup solvent in accordance wit h 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 cle aning 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 t o coating, necessary to meet a standard or specification issued or approved by the United States Department of Defense, Federal Aviation Administration or other fed eral government entity. Any person claiming exemption pursuant to this clau se shall maintai n 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) Associa ted 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 demo nstrate 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 Ad ministrator. A ny request for approval shall be made in writing to the commis sioner and Admin istrator and shall include a description of the cleaning sol vent 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

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- 39 Rev. 02/2012

Sec. 5. Section 22a

- 174

- 20 of the Regulations of Connecticut State Agencies is amended by the addi tion 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
pr essure, without compressed air, to atomize the coating;

(B) “Air

- assisted airless spray application” means a co ating 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 app lied 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 plea sure craf t 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 percent age;

(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 defini tion of “volatile organic compound” as defined in sectio n 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 topco at for purposes of providin g corrosion resistance, adhesion of subsequent coatings, a moisture barrier or promotion of a uniform surface n ecessary for filling in surface imperfections;

(L) “Flow coating” means a non

- atomized technique of applying coating in a fan pattern to a subst rate using a fluid nozzle with no air supplied to the nozzle;Page 29 of 36

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- 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 applicati on of a topcoat for purposes of providing corrosion resista nce, adhesion of sub sequent coatings, a moisture barrier or promotion of a uniform surface ne cessary 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 s ystem 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 c a pture 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 polyes ter resin (fiberglass), applied to a pleasure craft o r to parts and components of a pleasure craft;

(S) “Pretreatment wash primer” means a coating, contain ing at least 0.1 percent acid by weight and no more than 25 percent solids by weight, that is used to prov ide 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) P leasure craft or parts and components of pleasure craft prior to the application of coatings,

(ii) P leasure craft or parts and components of pleasure craft between coating applications, or

(iii) T ransfer lines, storage tanks, spray booths, and c oating application equipment; and

(U) "Transfer efficiency" means the portion of coat ing 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 app licator.

(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 commerci al 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 , orPage 30 of 36

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- 39 Rev. 02/2012

(ii) Such owner or operator purchases for use in all pleasure craft coating and related clea ning at the premises 855 gallons or more of coatings and cleaning solvents in
aggreg ate 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 requi rements 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 subse ction upon commencing operation; and

(C) Any owner or operator subject to this sub section 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 thi s 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 ) T he requirements of this subsection shall not apply to any of th e 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 subsection s of this section: (l) through (s) and (hh) 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) An owner or operator operat ing 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

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- 39 Rev. 02/2012

(4) On and after January 1, 2013 , no owner or operator of a pleasure craft coating operation shall
ap ply 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 V OC content no greater than the app licable level in Table 20(kk)

- 1;

(B) Use a combination of low

- VOC coatings an d add

- on air pollution control equipment to achieve a VOC emission rate no greater than the appl icable level in Table 20(kk)

- 2;

(C) Install, operate and maintain according to the manufacturer’s rec ommendations air pollution control equipment with an overall con trol efficiency of at least 90%;

(D) Use an alternative means, achieving a level of control equivalent to s ubparagraph (A), (B) or (C) of this subdivision, as requ ested from and approved by the c ommissioner

, in accordance with subs ection (cc) of this section; or

(E) Limit the total potential VOC emissions from all ple asure craft coating operations and related cleaning by permit or order of the c ommissioner to 1,666 pounds or less in any calendar mont h.

(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 a pplication;

(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
ope ration 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) W ork 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

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- 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 VOC

containing coating or solvent, shall be stored in a closed, nonabsorbe nt, 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 descripti on 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 solve nt:

(I) Purchased, or

(II) U sed,

(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 capt ure 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 ) Al l 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 lim its 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

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- 39 Rev. 02/2012

Where: Ws = weight of volatile compounds in grams

Ww = weight of water in grams

Wes = w eight 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 formu lation 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 pe rson 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, th e 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 42 0 3.5 Pretreatment wash primer 780 6.5 Finish primer or surfacer E ffective until December 31, 2015 : 600 Effective January 1, 2016 : 420 E ffective until

December 31, 2015 : 5.0 Effective January 1, 2016 : 3.5 High build primer or surfacer 340 2.8
A ntifouli ng coating

– aluminum substrate 560 4.7 A ntifouling 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 3.5Page 34 of 36

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- 39 Rev. 02/2012
Table 20(kk)

- 2

Pleasure Craft Surface Coatin g 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 E ffective until December 31, 2015 : 1870 Effe ctive 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
A ntifouling coating

– aluminum substrate 1530 12.8 A ntifouling coating

– all other substrates 764 6.4
Antifoul ing 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) e missions 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 nation al 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 Depart ment 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, DE E P is proposing to add more stri ngent 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, D E EP is proposing new requirements for addition to RCSA section 22a

- 174

- 20 to limit VOC emi ssions 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 m iscellaneous 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 th e 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 keepi ng 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 fo r alternative emissions control scena rios 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-- /~/~ "~-~4~’’{r/"~ Section 4-170, as amended 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 HearingPage 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 enhanceexisting reasonably available control technology (RACT) requirements for miscellaneous metal and plastic parts coating activities. EPA established a new RACT levelSeptember 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 thefederal 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 businesshours 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 AttendeesATTENDANCE 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 ReportConnecticut 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 coatingcategories, 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 primercoating and before the application of a subsequent coating (e.g., primersurfacer). The primary purpose of automobile and light-duty truck sealer is to



### 8fill 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 an d 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

20Attachment 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. Inaddition, 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. BaenaAttachment 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 testplate 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 aRpl g 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~.~g

340 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-componentElectric 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 88026

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 backingPrefabricated architectural multicomponentPrefabricated 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____QO

6.6~7 _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 9.7828

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 Plasti c 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 4,80DRAFT

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 coatingoperation 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 recordDRAFT 

### 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.DRAFT 

### 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

### DRAFT



## (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.

### DRAFT 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

DRAFT

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.

### DRAFT 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.DRAFT 

### 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;

### DRAFT 

### 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

"

~ " t c at" ]!~p~amlde op o 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 FederalAviation 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 - exterior oarts 

### 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 vehicle deadene__£r 

## 65__Q0 Motor vel

### 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 BakDRAFT 

### 29

_Coating Cat ego_L.W

General 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 backingPrefabricated architectural multicomponentPrefabricated 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/~al solid--~- 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 coatingoperation 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 perfor m 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 thatDRAFT 

### 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) (ld 0 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

R eport of the Legislativ e Commissioners’ Office1 

# 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 C oncerning 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 prej udice at the committee's meeting on July 24, 2012. The resubmittal addr esses 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, 20124 Sec. 22a-174. (Formerly Sec. 19-508). Pow ers of the commissioner. Regulations. Fees. Exemptions. General permits. Appe al 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 re peal regulations to control and prohibit air pollution throughout the state or in such ar eas 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 municipali ties for available federal grants. Any person heard at the public hearing on any such regul ation 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 mu ltistate air pollution control programs, for special studies, advice and assi stance; to consult with and advise and exchange information with other departments or agencies of the stat e; and (2) serve on the boa rd of directors of a nonprofit corporation, including, bu t not limited to, a nonprofit co rporation 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 regu lations adopted by him, (1) to require that a person, before undertaking the construction, installation, enlargement or establishment of a new air c ontaminant source specifie d in the regulations adopted under subsection (a) of this section, submit to him plan s, 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 a nd permitting the constr uction, installation, enlargement or establishment of the new ai r contaminant source in accordance with such plans, or to issue an order requiring that su ch plans and specifications be modified as a condition to his approving them and issu ing a permit allowing such construction, installation, enlargement or establishment in accordance therewith, or to issue an order rejecting such plans and specifications and prohibiting constr uction, installation, enlargement or establishment of a new air c ontaminant source in accordance with the plans and specifications submitted; (3) to require periodic inspection and maintenance of combustion equipment and other sources of ai r 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 subs ection (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 ai r pollutants, (B) burns waste oil, (C) is allowed by the5 commissioner, pursuant to regu lations adopted under subsec tion (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, orde r 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 s ubsection register with him and provide such information as he deems necessary to mainta in his inventory of ai r pollution sources and the commissioner may require renewal of such registration at interval s he deems necessary to maintain such inventory; (7) to requ ire 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 Amendmen ts of 1990; and (9) notwithstanding any regulation adopted under this ch apter, to require that any source permitted under Title V of the federal Clean Air Act Amendments of 1990 sh all comply with all applicable standards set forth in the Code of Federal Regu lations, 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 chap ter and section 14-164c.

(e) As used in this subsec tion, "contiguous" means abutti ng or adjoining without consideration of the actual or projected existence of roadways , walkways, plazas, parks or other minor intervening features; "indirect s ource" 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 emitte d. The commissioner shall not require the submission of plans and specifications under in direct source regulations adopted pursuant to subdivisions (1) and (2) of subsection (c) of this section for propos ed construction to be undertaken within a redevelopment area or ur ban 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 pr oposed 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 i ssue any order pursuant to subdivision (1) of subsection (c) of this secti on pertaining to the enforcement of indirect source regulations with respect to such propos ed 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 re quire the renewal of an i ndirect source operating permit6 issued in accordance with subsection (c) of th is 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 burni ng of brush on residential property, provided the burning is conducted by the resident of the pr operty or the agent of the resident and a permit for such burning is obtai ned 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 muni cipal recycling centers, provided a permit for such burning is obtained from the fire marsha l of the municipality where the facility is located, except that no open burning of brus h shall occur (1) when national or state ambient air quality standards may be exceed ed; (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 ad visory from the commissioner of any air pollution episode; (5) where prohibited by an or dinance 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 comm issioner. A permit for the burning of brush at any municipal landfill, munici pal transfer station or munici pal recycling center shall be issued no more than six times in any calenda r year. The proposed permit to burn brush at any municipal landfill, municipa l transfer station or municipal recycl ing center shall be submitted to the commissioner by the fire marsha l, with the approval of the chief elected official of the municipality in which the muni cipal landfill, municipa l transfer station or municipal recycling center is located. The commissioner shall appr ove or disapprove the fire marshal's proposed permitting of burning of brush at a municipal landfill, municipal transfer station or municipal re cycling center within a reasonable time of the filing of such application. The burning of leaves, demolition wa ste or other solid waste deposited in such landfill shall be prohibited. The burning of nonpr ocessed 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 s ubsection shall affect the power of any municipality to regulate or ban the open burning of brush w ithin its boundaries for any purpose. Notwithstanding any other provision of this section, fire break s 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 jurisdic tion over the area where the burning will occur issues an open burning permit: Fire-training exercises; eradication or control of insect infestations or disease; agri cultural purposes; clearing vegetative debris following a natural disaster; and vegetative management or enha ncement of wildlife habitat or ecological sustainability on municipal property or on any privately owned property permanently7 dedicated as open space. Open burning for such purposes on state property may be engaged in with the written approval of the commissione r. Local burning officials nominated for the purposes of this subsect ion shall be nominated only by the chief executive officer of the municipa lity 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 acco rdance with the provisions of chapter 54, governing open burning and may authorize or pr ohibit open burning consistent with this section. The regulations may require the paymen t of an application fee and inspection fee and may establish a certification proc edure for local burning officials.

(g) The commissioner shall require, by regulatio ns adopted in accordance with the provisions of chapter 54, the payment of a pe rmit 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, an y state or federal permit, license, order, certificate or approval require d pursuant to this section. Any person obtaining a permit, pursuant to said regulations, for the construc tion or operation of a s ource of air pollution or for modification to an existing source of air pollution shall subm it 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 a pplication fee of tw o hundred dollars.

(h) The commissioner may require, by regula tions adopted in accordance with the provisions of chapter 54, paymen t of a fee by the owner or op erator 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 f ee may not exceed the average cost to the department for the conduct or monitoring of su ch 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 deposit ed in the General Fund and credited to the appropriations of the Department of Ener gy and Environmental Protection in accordance with the provisions of section 4-86.

(i) Notwithstanding the provisions of subsec tions (g) and (h) of this section, no municipality shall be required to pay more than fifty per cen t of any fee established by the commissioner pursuant to said subsections.

(j) Fees or increased fees prescribed by this se ction shall not be applicable to residential property.

(k) (1) The commissioner may issue a general perm it with respect to a category of new or existing stationary air pollu tion sources, except with respect to a source which is already covered by an individual permit, provided the general permit is not inconsistent with the8 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. A ny person conducting an activity for which a general permit has been issued shall not be re quired to obtain an individual permit under this section, except as provide d in subdivision (5) of this subsection. The general permit may regulate a category of sources which, wh ether or not requir ing 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 appropriatel y controlled under a general permit than under an individual perm it. The general permit may require that any person proposing to conduct a ny activity under the general permit register such activity, including obtaining approval from the commi ssioner, 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 practi ces and verification and reporting requirements. Any such reports sh all be made available to the public by the commissioner. The commissioner shall grant an application for a pproval under a general permit without repeating the notice and comment procedures provided under subdivision (2) of this subsection, and such a grant shal l not be subject to judicial review under subdivision (4) of this subsect ion. Registrations and applic ations for approval under the general permit shall be submitted on forms prescribed by the commissioner; application forms concerning activities regu lated under the federal Clean Ai r 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) inte nt to issue a general permit, (ii) the right to inspect the proposed general permit, (iii) th e opportunity to submit written comments thereon, and (iv) the right to a public hearing if , within the comment period, the commissioner receiv es 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 subj ect 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 subpara graph (A) of this subdivision during which interest ed persons may submit written comments concerning the permit to the commissioner; (D) the commissi oner shall not issue the general permit until9 after the comment period and th e 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 pers on may request that the commissioner issue, modify, revoke or suspend a general perm it in accordance with this subsection.

(3) Any general permit under this subsection sha ll be issued for a fixed term. A general permit covering an activity regulated under the fe deral Clean Air Act shall be issued for a term of no more than five years. A general permit covering an activ ity regulated under the federal Clean Air Act shall contain such addi tional conditions as may be required by that

act.

(4) Notwithstanding any other provis ion of this chapter and ch apter 54, with respect to a general permit concerning activit ies 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 provision s 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, ai r and waters of the state fr om pollution. The commissioner may require an individual permit under this s ubdivision in cases including, but not limited to, the following: (A) The permittee is not in co mpliance with the conditions of the general permit; (B) a change has occurred in the av ailability of demonstrated technology or practices for the control or abatement of pollu tion applicable to the permitted activity; (C) circumstances have changed since the time th e 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 a pplicability of the federal Clean Air Act. In making the determination to require an indivi dual permit, the commissioner may consider the location, character and size of the s ource and any other rele vant factors. The commissioner may require an individual perm it under this subdivision only if the person whose activity is covered by the general perm it 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 applicati on form, a statement setting a time for the person to file the application and a statement that the genera l permit as it applies to such person shall automatically terminate on the eff ective date of the individual permit. Such person shall forthwith apply for, and use best efforts to obta in, 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 enti tled under said section to obtain judicial review of the commissioner's final action on su ch application may appeal such action in accordance with the provisions of section 4-183.

(m) The commissioner shall not issue a permit fo r an asphalt batch plant or continuous mix facility under the provisions of this sec tion until July 1, 2004, unless the commissioner determines that the issuance of the permit w ill result in an improvement of environmental performance of an existing asphalt batch plan t 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, repl acing, consolidating or ot herwise altering the physical plant of an existing facility provided such upgrade, replacement, consolidation or alteration results in an improvement of envi ronmental performance or in reduced total emissions of air pollutants.Attachment G

Regulatory Assessment DocumentRegu latory 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 (CTDE E P) 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 consider ations pertinent to the proposal and the expected air quality benefits of the proposal.

This RAD is intended to help both CTDE E P staff and the regulated community understand what is intended by the proposal. However, if any statement in this document i s 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 pollu tants 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 imp acts, 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 pollutant s. 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 mat ter. For each nonattainment area, CT DE E P has developed a plan that describe s how the state will attain the ambient air quality standards, which generally involves implementing a suite of2

measures that will reduce direct emissions of the pollutant of conce rn or reduce emissions of precursor pollutants.

In February 2008, CT DE E P 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), Connecti cut’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 b y 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 I mplementation 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, a nd 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 impleme nt 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 pro vide state and local air pollution control authorities wit h information for determining RACT for VOC emissions from miscellaneous metal and plastic parts coating operations. 1 Connecticut is proposing revisions to section 22a

174

- 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 CT DE E P first adopted as RCSA section 22a

- 174

- 20(s) i n 1980 and revised in 1993 to increase compliance flexibility. CT DE E P 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, CT DE E P is proposing to address pleasure craft coating with regulatory requirements separate from those applying to met al 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

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- 20.

III. Descri ption of Regulatory Requirements This section describes the basic elements of proposed subsection s (s) and (kk) of RCSA section 22a

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- 20. Information about the considerations underlying each element is provided in Section IV.

People operating potenti ally regulated coating operations should keep in mind that RCSA section 22a

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- 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

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- 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 RCS A section 22a

- 174

- 20. The applicability threshold for the CTG

- based subsections of RCSA section 22a

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- 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 oper ation 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

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- 20(s) or section 22a

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- 20(kk), respectively. Additionally, any owner or operator subject to section 22a

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- 20(s) before January 1, 2012 must comply with either amended secti on 22a

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- 20(s) or new section 22a

174

- 20(kk), as appropriate.

B. Exemptions and Exceptions Proposed subsection s (s) and (kk) both include exemptions recommended in the 2008 CTG, such as an exemption for coatings applie d with a hand

- held aerosol can; a nd 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 r egulations.

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 (NESHA P) results in an equivalent level of control as the 2008 CTG, and so CTDE E P 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 CTDE E P 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 subsectio n (s) and subsection (kk) include exemption s 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 alon e triggering compliance measures. Subsection (s) also allows an owner to petition the commissioner to use more than 55

- gallons of non compliant coatings, with sufficient justification for such use.

Other exemptions in subsection (s) were added in respon se 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 th e operation is not an activity subject to the requirements of subsection (s).

C. Compliance Options Sections 22a

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- 20(s) and 22a

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- 20(kk) provide three primary options for controlling VOC emissions: (1) VOC content limits for each coating category b ased 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 ove rall 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 materi als 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 use d on a single coating unit. CT DE E P reserves the use of averaging only for sources that require an alternative compliance option through a consent order issued under RCSA section 22a

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- 20(cc).

An owner or operator may also choose to control VOC emissi ons under sections 22a

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- 20(s) and 22a

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- 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 or der 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, a ny miscellaneous metal and plasti c 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 fac ility will be in violation.

D. Record Keeping Owners and operators of s ources subject to either RCSA section 22a

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- 20(s) or 22a

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- 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 i nclude a compliance date of June 1, 2012. Depending on the speed with which this proposal moves towards adoption, CTDE E P intends to adjust the compliance date to follow the adoption date of the proposal, with some months for CTDE E P to engage in outreach
t o 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 CTDE E P developed subsections (s) and (kk) in an iterative drafting approach that included consultation with other divisions of CTDE E P, EPA, consultants and representative of regulated industries.

Subsec tion (s) of RCSA section 22a

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- 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 th e 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 draf t, which included pleasure craft coating as a type of miscellaneous metal and plastic parts coating, was first provided to CTDE E P’s advisory committee, SIPRAC, 4 in February 2010.

Meetings were held with a volunteer subcommittee of SIPRAC, which subcommi ttee 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 Febru ary, 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 mee tings, 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, CTDE E P Boating Division and the Office of Long Island Sound P rograms attended.

CTDE E P is particularly grateful to Bob McConnell of EPA Region 1 who provided information and expertise throughout the drafting process. Responses to our quest ions often required research or intera ctions 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=16196

B. Approach A number of issues addressed during regulatory development are discussed here.

Two Sets of R equirements

. 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. CT DE E P chose to separate surface coating requirements for pleasure craft from section 22a

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- 20(s) and promulgate the pleasure craft requirements as new section 22a

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- 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 usua lly coated out

- of

- doors at a marina. Further, p leasure craft coating is concentrated during a few months each year, while job shops typically operate relatively constantly throughout the year. Historically, EPA and CT DE E P have had an established regulato ry 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 response 5 to the American Coating s Association (ACA) request for reconsideration of the 2008 CTG was instrumental to CTDE E P’s decision to regulate the miscellaneous metal and plastic parts coating operations separate from pleasure craft coating operations. ACA had asked for EPA’s reconsi deration 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 en couraged 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 . CTDE E P understood the EPA request to provide suffic ient 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

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- 20(s) determines the app licability of an operation based on daily emissions. Exceeding the threshold even once requires an operation to continue to operate under RCSA section 22a

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- 20(s) in perpetuity. EPA refers to this approach as the “once in, always in” RACT policy. CTDE E P 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

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- 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.

Applicabi lity

. While CTDE E P historically has set the applicability for CTG

- based requirements using a daily averaging period, CTDE E P finds that a 12

- month rolling averaging period, which is acceptable under the CTG, is more appropriate to our current air quality n eeds 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 regulate d. The daily averaging period resulted in an operation that had a very high level of operation for only a sin gle 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.

I n combination with the change in the averaging period for the applicability, CTDE E P 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 environmental ly sophisticated business owners . The use of a 12

- month rolling period and materials purchased to determine applicability are proposed for both subsection s (s) and (kk).

Some purchased materials are not included in the total to determine applicability, namely the

co atings and cleaning solvents that are listed as exempt.

Concerning applicability determinations and pleasure c raft 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 oz one season and boating season are coincident.

Section 22a

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- 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 l ocated 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

c leaning. Discussions with our stakeholder s 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 in cludes 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 c leaning or cleaning of parts subject to a distinct set of requirements in RCSA section 22a

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- 20 or another regulation.

CTDE E P added a definition of “related cleaning” to subsection (s) and subsection (kk) to make its intent clear. For example, the de finition added to subsection (s) is as follows:

“Related cleaning” means the removal of un cured 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; or8

(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 t o obtain a permit. An owner subject to the requirements of RCSA section 22a

- 174

- 20 should also verify the applicability of RCSA section 22a

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- 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 secti on 22a

- 174

- 18 to apply to pleasure craft coating or sandblasting. I f 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 g eneral 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 s ection 22a

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- 20(ii) includes an exemption for cleaning conducted under RCSA section 22a

- 174

- 20(s). No similar exemption is included in RCSA section 22a

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- 20(jj), which regulates spray gun cleaning. As RCSA section 22a

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- 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 appl icability 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 activiti es that are subject to the NESHA P are not reg ulated 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 22 a

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- 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 specificatio n 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 qua ntity of military specification coating used in the state is small, CTDEEP concluded

6 Control Techniques Guide lines: 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 regula ted 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 Ant ifoulant Coating, and Antifouling Sealer/Tie Coating are less stringent than recommended in the CTG.

CTDE E P chose to reduce the VOC content limits on recommendation and information supplied by the American Coatings Association (ACA) during the preparati on 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 t hree 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 rec ommended for a VOC content limit of 330g/L, even though the Shipbuilding and Repair NESHAP and SCAQMD Marine Rul e 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 mor e applications than the higher VOC content coatings, potentially resulting in more environmental detriment overall given the nature of antifouling coatings.

For finish primer/surface, CTDE E P 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.

CTDE E P also added a new category for pleasure craft coating, antifouling s ealer/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 num ber 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 larg e 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 incl udes 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 also10

confounded because a single source may be counted multiple times if the source engages in activities in several NAICS categories.

CT DE E P used EPA’s list of NAICS codes for potentially regulated sources to search the U.S. Census Bureau’s 2007 eco nomic 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. CT DE E P’s estimate of 361 potentially impacted s mall 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 wi th emissions below the applicability threshold of RCSA section 22a

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- 20(s), a s 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 di fficult 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. CT DE E P 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 a s a secondary part of their business. Any such facility that engages in commercial boat coating or re

- coating would be subject to the requirements o f proposed RCSA section 22a

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- 20(kk).

VI. Economic and Small Business Impact The anticipated financi al 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 f acilities 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 an d 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 coat ings. 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, applicabilit y 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 admin istrative 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 ci rcumstances 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 wil l 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 becaus e 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