STATE OF CONNECTICUT 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

HEARING REPORT 

Prepared Pursuant to 

40 Code of Federal Regulations Section 51.102 

Regarding a Revision to the State Implementation Plan: 

Reasonably Available Control Technology (RACT) Update 

Hearing Officer: 

Merrily A. Gere 

Date of Hearing: August 27, 2009 

On July 27, 2009, the Commissioner of the Department of Environmental Protection (CTDEP) 

published a notice of intent to revise the State Implementation Plan (SIP) for air quality to: (1) 

address the visibility protection requirements of section 169A of the federal Clean Air Act 

(CAA); and (2) update RACT requirements, given the promulgation of eleven federal control 

techniques guidelines (CTGs) in 2006 through 2008 . Pursuant to such notice, a public hearing 

was held on August 27, 2009, with the public comment period closing on August 28, 2009. This 

hearing report addresses only the RACT update proposal, comment and final recommended SIP 

revision . 

I. Hearing Report Content 

This report describes the revision to the SIP as proposed for hearing; the comment made and a 

response thereto; and the final recommendation based on the proposal and comment received . 

II. Summary and Purpose of Proposal 

On February 1, 2008, CTDEP submitted to the U.S . Environmental Protection Agency (EPA) an 

attainment demonstration SIP revision for the 1997 8-hour ozone national ambient air quality 

standard . That attainment demonstration includes an analysis of how Connecticut's SIP 

complies with the RACT requirements of the CAA. EPA's adoption of eleven CTGs in 2006 

through 2008 requires that CTDEP update its RACT analysis. In the proposed SIP revision, 

CTDEP makes negative declarations for three CTG source categories (flat wood paneling 

coating, fiberglass boat manufacturing, automobile and light-duty truck assembly coating) ; 

provides a statement of equivalency for one CTG (miscellaneous industrial adhesives) ; and 

indicates the status of pending CTDEP regulatory revisions for the seven remaining CTGs 

(industrial cleaning solvents ; offset lithographic printing and letterpress printing; flexible 

package printing; paper, film and foil coating; large appliance coating; metal furniture coating; 

miscellaneous metal and plastic parts coating) . 

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79 Elm Street * Hartford, CT 06106-5127 

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111. Summary of Comments 

EPA was the only commenter on the SIP proposal, as follows: 

Anne Arnold, Manager 

Air Quality Planning Unit 

U.S . Environmental Protection Agency 

Region 1 

1 Congress Street, Suite 1100 

Boston, MA 02114-2023 

Mcconnell.robert@epamail.epa.gov 

EPA's comment is summarized below with CTDEP's response. 

Comment: CTDEP's RACT update to address CTGs issued by EPA in 2006 through 2008 

includes a determination that the state's existing adhesives and sealants rule (section 22a-174-44 

of the Regulations of Connecticut State Agencies (RCSA)) represents an equivalent level of 

control as compared to EPA' s CTG for miscellaneous industrial adhesives. In most cases, the 

VOC emission limits of Connecticut's rule and EPA's CTG are identical, although some 

differences do exist. For example, EPA's limit for wood adhesives (30 grams/liter) is more 

stringent than the comparable limit in Connecticut's rule (120 grams/liter), but Connecticut's 

limit for automotive glass adhesive primer (700 grams/liter) is more stringent than the 

comparable limit in EPA's CTG (900 grams/liter) . In addition to these emission limits, there are 

other potentially more significant differences that Connecticut should consider in making the 

equivalency determination. 

" For example, EPA's CTG contains a recommendation that certain application methods 

such as electrostatic spray, high volume low pressure (HVLP) spray, and airless spray 

methods be used in conjunction with the recommended VOC emission limits. 

Connecticut's adhesives and sealant rule does not address this . We note that other 

Connecticut rules, such as RCSA section 22a-174-3c regarding automotive refinishing 

operations, do contain application method requirements . 

" Additionally, although both the Connecticut rule and EPA's CTG contain many similar 

exemptions, Connecticut's rule includes additional exemptions not found in the CTG. 

For example, subsection (c)(9) of RCSA section 22a-174-44 provides an exemption for 

the United States military. This provision, as currently structured, is very broad and does 

not require any type of showing be made that the emission limits within Connecticut's 

rule are impracticable for the military to meet. Given the fairly large number of U.S. 

military facilities in Connecticut, this exemption is likely to lower the emission reduction 

potential of the state s rule . 

Response: RCSA section 22a-174-44 differs from the CTG recommendations in one 

aspect crucial to Connecticut's view of RCSA section 22a-174-44 as equivalent. RCSA 

section 22a-174-44 applies to manufacturers, sellers and users of regulated products, 

while the CTG recommendations only apply to users of regulated products at industrial 

facilities . The much greater breadth of Connecticut's applicability produces emissions 

reductions beyond those of the CTG recommendations, which makes up for any 
decreased emissions benefits that may result from the lack of specific application 

techniques] and additional exemptions. Furthermore, the CTG recommendations do not 

include adhesives applied to EPDM single-ply roof membrane, the dominant single-ply 

roof material in Connecticut, which, by some estimates, is alone responsible for as much 

as 25% of Connecticut's summer day emissions from regulated adhesives and sealants. 

For these two differences in applicability, CTDEP maintains that the emissions benefits 

of RCSA section 22a-174-44 are at least equivalent to, if not greater than, the emissions 

benefits of the CTG recommendations for miscellaneous industrial adhesives. CTDEP 

should submit the RACT update SIP without revision to the discussion of RCSA section 

22a-174-44. 

IV. Hearing Officer Comment 

Final regulations that are responsive to six of the CTGs discussed in Table 2 of the RACT update 

have been adopted, effective April 6, 2010. Table 2 and the text discussing Table 2 should be 

revised consistent with the adoption of the CTG-based regulatory requirements, and the newly 

adopted regulatory requirements should be submitted to EPA with the RACT update . 

V. Conclusion 

I recommend that the proposed RACT update SIP revision be revised as recommended in this 

report and be submitted to EPA for approval. 

April 28, 2010 

Date 

' DEP's experience is that industrial users of adhesives and coatings use those application methods that 

reduce waste because they are cost effective; such waste reducing methods often happen to be those same methods 

that reduce VOC emissions.