COUNTYOF ALLEGHENY 

RICH FITZGERALD 

COUNTY ExECUTIVE 

August 14, 20 IS 

Ms. Joyce Epps, Director 

Department of nvironmental Protection 

Bureau of Air Quality 

Rachel Carson Building 

400 Market Str et. P.O. Box 8468 

Harrisburg, PA 17105-8468 

Dear Ms. Epps: 

With this letter, The Allegheny County Health Department is submitting the nece sary 

documentation to PA DEP for review and approval to request EPA's approval of this propo d 

revision to Allegheny County's portion of the Pennsylvania State Implementation Plan. The 

purpose of this revision request is to amend Article XX I, Air Pollution Control Rules and 

Regulations [and ounty Ordinance 16782] Section 2105.86" ontrolof YOC missions from 

Fiberglass Boat Manufacturing Materials to include the previously omitted table 2105 .86 

labeled Monomer YOC Content Limitations for Open Molding Resin and (lei Coat 

Operations." This SIP revision is being tracked as a supplement to our internal Revision 

Tracking umber 74. 

As described in the Technical SUppOIi Document of the attached supplemental submittal, I able 

2105.86 was inadvertently omitted during the original preparation and approval process or 

Article XXI, Section s: I 05.86. This rule change became efTedive in Allegheny County initially 

on June 8. 2013. and was subsequently ubmitted to the U.S. EPA as a SIP Revision 74 along 

with three other YOC ~mission limiting regulations on Nuvember 15,2013. During the course 

of conducting a review of the rule. PA determined that the table was missing. 

EPA promulgated a "conditional approval" of the SIP submittal consistent with 'lean Air ct 

Section 11 0(k)(4) if ACHD, within one year, amends and submits a revised Section 2105.86 to 

EPA to COlT ct the omitted table. With this understanding, ACIID committed to DEP in the 

attached Jetter dated June 26. 2014 to promptly revise Al1ic\e XXI. Section 2105 .86. byaddin!! 

Table 2105.86. DEP committed in tum to suhmit this change to EPA within one year from the 

Federal Register publication of final notice of conditional approval. Please reference DE P lettcr 

dated July IG. 2014. included in the submittal. and the proposed and final ruh::s 79 FR 51515. 

dated August 29. 2014, and 79FR70470 dated November 26, 2014, respectively that address the 

conditional approval. 

KAREN HACKER, MD. MPH, DIRECTOR 

ALLEGHENY COUNTY HEALTH DEPARTMENT 


AIR QUAUTY PROGRAM 


30 1 39lH STREET • CLACK HEALTH CENTER • BUILDING 7 


PnTsBuRGH. PA 15201 -181 1 


PHONE (4 12) 5788 103 • FAX (41 2) 57881 44 


24+fR (4 12) 687·ACHD (2243) • WWW.ACHD.NET 
Supplemental SlP74 Submittal 

August J4. 20 I 5 

This SIP Revision was the subjcct ora public commentpcriod from September 12 20]4 until 

October 19.2014. with a public hearing held on October J4.20 J4, during which no comment 

were recei ed. It was approved by the Brxlrd of Health on November 5, 2U 14, enacted by unt 

Council on May 5, 2015. approved und signed 1"1~ the Allegheny County Chief 'xecutivc on Ma. 

8, 2015, and became effl ctive June 11}, 2015. 

ACHD followed all of the applicable procedural requirements of the Commonwea lth's laws and 

constitution in conducting and completing the adoption/issuance orthe supplemental SIP 

rc ision. A .HD also publishes the proposed SIP Revision on its website 

htLp://WW\ .achd.netiair/reguJations.htrnJ in accordance with PA Stat Act 27 of 20]2. 

As required by federal SIP-processing regulations. enclosed certifications that the required public 

notices were provided and that a public hearing was held. Those documents. includino th . e 

referenced in this letter art: included as a paper copy. and an exact duplicate orthis paper cop on 

a computer disk in seurchable pdf file fomlat. 

We request that the Pennsylvania Department of Environmental Protection approve this r ISl on 

and forward the paper copy and disk to the U.S. EPA Rcgion JIJ with a recommendation for 

approval in timc to meet the November 26, 2015 deadline. If you have any questions. pl ease c 11 

me at (412) 578-8103 or email mcat jgraham@achd.n 1. 

Sin erely. 

Lnj ...../ 1ra (1"­

ayme Graham, Manager 

Air Quality Program 

cc: 	 Kirit Dalal 

Stephen Hepler 

Enclosures 
Attachment to August 14 Supplemental Submittal Letter (Page 1 of3) 

COUNTY OF ALLEGHENY 

RICH FITZGERALD 


Co IN"';- EKEC 'F,'"'' 


June 26. 2014 

Ms. Joyce Epps, Director 

Bureau of Air Quality 

Department ofEm;ironmental Protection 

Rachel Carson Building 

400 Market Street 

PO Box 8468 

Hanisburg. PA 17105-8468 

Dear Ms. Epps: 

The purpose oflhis letter is to request your assistance ....ith an action pending before the C.S. 

Environmental Protection Agency (EPA) concemiJl@ the State Implementation Plan (SIP) 

Revision for the Allegheny County Health Department's Fiberglass Boal Manufacturing 

Materials regulation. 

On November 15.2013. the Pennsylvania Depanmenl ofED\'ironm"'1ltal Protection (OEP) 

submitted a revision to Pennsyhania's State Implementation Plan (SIP) pataining to the 

adoption by the Allegheny County Health Department CACHO) in June 2013 offour separate 

regulations implementing Control Techniques Guidelines (CTGs) promulgated by the U.S. 

Environmental Protection Agency (EPA) in 2008 for Miscellaneous Metal andior Plastic Parts 

Surface Coating Processes: Automobile and Light-Duty Truck Assembly Coatings; 

Miscellaneous Industrial Adhesives; and Fiberglass Boat Manufacturing Materials. The relision 

is identified as revision No. 74 to the Attainment and Maintenance Plan tor ACHO's internal 

tracking. 

As a result of its review. EPA has indicated that: 

(l) In Section 2105.86. "Control ofVoe Emissions from Fiberglass Boat Manufacturing 

~taterials," under Subsection c, "Limitations.~ Table 2105.86 (regarding average 

monomer VOC content limit) is referenced. but the table is not included in the submittal. 

(2) Gi,,·en that ACHO subsequently reported that the table had not been included as pan of 

the regulation that went out to public hearing, this omission is inconsistent with EPA's 

procedures for SIP revisions set rorth at 40 C.F.R. §51.102(d)(2) which requires the 

availability ofthe entire plan for public inspection. including that table. 

(3) The table of VOC emission limits is a significant pan ofthe regulation. and it is difficult 

for meaningful public comment ifthose emission limits are not available for public 

in~ction. and ACHD must comply with stale and tederal requin.'014.'11ts for notice and 

comment. 

ALL.EGHENY COUNTY HEALTH DEPAfltTMENT • AIR QUALITY PfIIOGRAM 


:iO~ ':I~ --STR£T~fL"x)"'C#I. PTTSBURI.; ... f,'A ':;,20'<0' 1 


p ..... O~f: 14"? f7~7B-8· .~~? " r A). '4 ~~) ~ 7HB ~.44 
Attachment to August 14 Supplemental Submittal Letter (Page 2 of3) 

To address the situation. EPA has offered a "conditionaJ appFO\'al" of the SIP submittal under 

Clean Air Act SC!Ction 11 O(k)(4) during which time ACHD would witbin one year amend and 

submit a re\ised Section 2105.86 to EPA, 

With this understanding. AJleghen~' County is requesting that you seek the Secretar)"s 

concurrence and signature in a letter to the EPA Region IlJ Administrator committing ACHD to 

f'e\ising Article XXI. Section 2105.86. which is before EPA for action pursuant to Section 

110(11:) of the Clean Air Act. by adding Table 2105.86 (shown in the attachment) within one year 

from the Federal Register publication of IinaJ notice of conditionaJ approval of ACtlD' s CTG 

SIP 74. In tum. ACHD commits to revising. Article XXI Section 2105.86 in a timely fashion that 

will allow DEP adequate time to miew and submit the re'\ised SIP to EPA within the one year 

time frame described above. 

ACHD is confident that this commitment can be met for the folll')\\ln8 reasons. 

(I ) The amount of technical work necessary tor the measure to be adopted is minimal The 

content ofthe table aJready exists in the CTG and must merely be placed into Article 

XXI. Section 2105.86. 

(2) Adoption of the measure is not expected to be controversial because then: are no related 

regUlated sources in Allegheny County. 

(3) The regulation revision can be adopted at the County level. and reviewed by PA DEP and 

forwarded to EPA in Ies.~ than one year. 

ACHD understands that this commitment will result in a conditional approvaJ by EPA of the 

pre\iously submitted CTG SIP re\ision No. 74 for Allegheny County. Upon EPA's approval of 

the SIP revision satisf}ing the rulemakins commitments. EPA' s conditional approval to the 

Allegheny portion of the Pennsylvania SIP \\ill become a full approval. 

EPA request prompt action so that tinaJ action may be taken on the SIP fe\ ision. 

Thank you for your assistance in this matter. 

Sincerely. I) 

efW~~v 

Jaymc Graham. Managl.'f 

Air Quality Program 

cc: Kirit Dalal 

Steve Hepler 

Enclosures: 

• Attachment 
Attachment to August 14 Supplemental Submittal Letter (Page 3 of3) 

AITACHME~I 

T.bI~ 1105.86 


Monomtr VOC Coattnt Limitations ror Opm Molding Resin aad Gtl Coat Operations 


It••erial 

Production Resin 

Production Resin 

Pigmented Gel Coat 

Clear Gc-I Coat 

Tooting Resin 

Tooling Resin 

Tooling Gel Coat 

Applisatiop Metbod W~ight Ave.... Monomer VOC Colleg, Limit 

(w••, Dtmat) 

Atomized (spray) 28 

SonaJomized ~w "oil

Any Method 33 

An) Method 48 

Atomized 30 

Nonatomized 39 

Any Method 40 
SUPPLEMENTAL TO SATISFY CONDITIONAL APPROVAL REQUIREMENT 

OF SIP REVISION 74 to ALLEGHENY COUNTY'S portion of the 

PENNSYLVANIA STATE IMPLEMENTATION PLAN 

For the 


Attainment and Maintenance of the National 


Ambient Air Quality Standards 


Revision Tracking No. 74 SUPPLEMENTAL 


Allegheny County Health Department 


Rules and Regulations 


Article XXI, Air Pollution Control 


§2105.86 CONTROL OF VOCS FROM FIBERGLASS BOAT 


MANUFACTURING MATERIALS 

Table of Contents 

1. 	 Change to Article XXI Rules and Regulations §2105.86, Control of vac 

Emissions from Fiberglass Boat Manufacturing Materials - addition of 

Table 2105.86. 

2. 	 Technical Support Document 

3. 	 Documentation of Public Hearing and Certifications 

Public hearing notice 

Transmittals of hearing notice to EPA & PA DEP 

Proof of publication of notice of hearing 

Certification of hearing 

Summary of Comments and responses 

Certifications of approval and adoption 
1. 


Regulation Revision - Addition of Table 2105.86 

Deletions are shown with strikethroughs. 


Additions are shown in lar2er font, bolded, and underlined. 


§2105.86 CONTROL OF VOC EMISSIONS FROM FIBERGLASS BOAT 

MANUFACTURING MATERIALS {Added May 29, 2013, ejfecliveJune8, 2013. Table 2105.86 

added May 8, 2015, ejfective May 18, 2015.} 

a. 	 Applicability. Beginning January 1,2014, this section applies to the owner or 

operator of a fiberglass boat manufacturing facility, where the total actual VOC 

emissions from fiberglass boat manufacturing materials, including related 

cleaning activities, at that facility are equal to or greater than 15 pounds (6.8 

kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling period, 

before controls. This regulation applies to facilities that manufacture hulls or 

decks of boats from fiberglass, or build molds to make fiberglass boat hulls or 

decks. This regulation does not apply to facilities that manufacture solely 

fiberglass parts of boats such as hatches, seats, lockers, or boat trailers. 

b. 	 Exemptions. This regulation does not extend to surface coatings applied to 

fiberglass boats, and industrial adhesives used in the assembly of fiberglass boats. 

Surface coating for fiberglass and metal recreational boats, also called pleasure 

crafts, are addressed in regulation § 2105.83 CONTROL OF VOC EMISSIONS 

FROM MISCELLANEOUS METAL AND/OR PLASTIC PARTS SURFACE 

COATING PROSSES. Industrial adhesives used in fiberglass boat assembly are 

addressed in regulation § 2105.85 CONTROL OF VOC EMISSIONS FROM 

MISCELLANEOUS INDUSTRIAL ADHESIVES. 

c. 	 Limitations. A person may not cause or permit the emission into the outdoor 

atmosphere ofVOCs from fiberglass boat manufacturing materials, unless one of 

the following limitations is met: 

I. 	 Fiberglass boat manufacturing facilities shall use resins and/or gel coats 

that are equal to or less than the applicable weighted average monomer 

VOC content limit specified in Table 2105.86 and the non-monomer VOC 

limit shall not exceed 5 percent, by weight, ofresin and/or gel coat. 

A. 	 The weighted average monomer VOC content shall be calculated 

as follows: 

I(Mj * VOCj) 

Weighted Average Monomer VOC Content = -------------­
Where: 

Mi = Mass of open molding resin or gel coat i used in the past 12 

months in an operation in pounds (kg) 

VOCj = Monomer VOC content, by weight percent, ofopen 

molding resin or gel coat i used in the past 12 months in an 

operation 

d. 	 Records. A facility, regardless of the facility's annual emission rate, which uses 

fiberglass boat manufacturing materials, shall maintain records sufficient to 

demonstrate compliance with this section. At a minimum, a facility shall 

maintain daily records of: 

1. 	 The following parameters for each material either resin and/or gel as 

supplied: 

A. 	 The name and identification number of each resin and/or gel; 

B. 	 The volume used; 

C. 	 The mass of materials used; 

D. 	 The monomer VOC content, by weight percent, of resin or gel coat 

used; 

The non-monomer VOC content, by weight percent, of each resin 

or gel coat; 

The records shall be maintained for 2 years and shall be submitted to the 

Department on a schedule reasonably prescribed by the Department. 

e. 	 Cleaning Material Standards. The VOC content of cleaning solvents employed 

for routine application equipment cleaning shall contain a maximum of 5 percent 

VOC, by weight, or have a composite partial vapor pressure of no more than 0.50 

mm Hg at sixty-eight degrees Fahrenheit. Only non-VOC solvents shall be used 

to remove cured resin and gel coat from application equipment. 

f. 	 Work Practice Standards. All resin and gel coat mixing containers with a 

capacity equal to or greater than 208 liters (55 gallons), including those used for 

onsite mixing of putties and polyputties, have a cover with no visible gaps in 

place at all times. This work practice standard does not apply when material is 

being manually added to or removed from a container, or when mixing or 

pumping equipment is being placed in or removed from a container. 

g. 	 Measurements. Measurements of the volatile fraction of resin and gels, used at 

fiberglass boat manufacturing facilities shall be performed according to the 

applicable procedures established in §2107.04 of this Article. 
(All material on this page is being added.) 

Table 2105.86 


Monomer VOC Content Limitations for Open Molding Resin and Gel 


Coat Operations 


Material Application Method Weight Average Monomer 

VOC Content Limit 

(weight percent) 

Production Resin Atomized (spray) 28 

Production Resin Nonatomized 35 

Pigmented Gel Coat Any Method 33 

Clear Gel Coat Any Method 48 

Tooling Resin Atomized 30 

Tooling Resin Nonatomized 39 

Tooling Gel Coat Any Method 40 
2. 

Technical Support Document 

The ACHD Air Quality Program is updating Article XXI, Section 2105.86, "Control ofVOC 

Emissions from Fiberglass Boat Manufacturing Materials," by adding Table 2105.86, "Monomer 

VOC Content Limitations for Open Molding Resin and Gel Coat Operations." 

The table was inadvertently omitted during the preparation and approval process of Section 

2105.86 which became effective initially on June 8, 2013, and which was subsequently submitted 

to the U.S. EPA as a SIP Revision (internal tracking number SIP74) along with three other VOC 

emission limiting regulations *. 

During the course of conducting its review, EPA determined that the table, which is referenced in 

Section 2105.86.c, "Limitations," was missing. 

To address the situation, EPA offered a "conditional approval" of the SIP submittal under Clean 

Air Act Section 110(k)(4) ifACHD, within one year, amends and submits a revised Section 

2105.86 to EPA. With this understanding, ACHD has committed to DEP to promptly revise 

Article XXI, Section 2105.86, by adding Table 2105.86. DEP will then submit this change to 

EPA within one year from the Federal Register publication offinal notice of conditional 

approval. (Reference DEP letter dated July 16,2014 and 79 FR 51515**, dated August 29, 

2014.) 

With respect to the contents of Table 2105.86, "Monomer VOC Content Limitations for Open 

Molding Resin and Gel Coat Operations," they were taken directly from Control Techniques 

Guidelines for Fiberglass Boat Manufacturing Materials (U.S. EPA, EPA·453/R·08·004, 

September 2008). Found on page 27, the corresponding Table in the CTG is Table 3, "Compliant 

Materials Monomer VOC Content Recommendations for Open Molding Resin and Gel 

Coat." The material, application method, and weighted average monomer VOC content (weight 

percent) limit in Table 3 ofthe CTG Fiberglass Boat Manufacturing Materials, are identical to 

that found in Table 2105.86 to be added by this revision to ACHD's corresponding regulation, 

Article XXI, Section 2105.86. 

*2105.83, "Control ofVOC Emissions from Miscellaneous Metal and/or Plastic Parts Surface 

Coating Processes;" 

2105.84, "Control ofVOC Emissions from Automobile and Light Duty Truck Assembly 

Coatings;" and 

2105.85, "Control ofVOC Emissions from Miscellaneous Industrial Adhesives." 

**79 FR 51515, August 29, 2014, "Approval and Promulgation ofAir Quality Implementation 

Plans: Pennsylvania; Allegheny County's Adoption of Control Techniques Guidelines for Four 

Industry Categories for Control of Volatile Organic Compound Emissions," Proposed Rule. 
8' P.,,!!!~~!~~'~~n~m", SECRETARY 

July 16, 2014 

Shawn M. Garvin 


Regional Administrntor 


U.S. Environmental Protection Agency. Region Ul 


1650 Areh Street (Mail Code: 3RAOO) 


Philadelphia, fA 191()3·2029 


Dear Mr. Garvin: 

On November 15, 2013, the Pennsylvania Department of Environmental Protection (DEP) 


submitted a revision to Pennsylvania's State Implementation Plan (SIP) pertaining to the 


adoption by Allegheny County Health Department (AClID) in June 2013 offour sepanlte 


regulations implementing Control Tcchniques Guidelines (CTO) issued by the 


U.S. Environmental Protection Agency (EPA) in 2008 for Miscellaneous Metal and/or Plastic 

Parts Surface Coating ~$SCs; Automobile and Light-Duty Truck Assembly Coatings; 

Miscellaneous industrial Adhesives; and Fibergla.~s Boat Manufacturing Materials. The revision 

is identified as revisiou 14 for ACHD's internal tracking. 

The EPA reviewed the SIP revision. As a result orits review, EPA indicated that 

Section 2105.86 (relating to Control ofVOC Emissions from Fiberglass Boat Manufacturing 

Materials) referenced Table 2105.86 (average monomer VOC content limit), but Table 210.5.86 

WllS not included in the llUbmittal. ACliD subsequently reported that the table had not been 

included ns part of the regUlation that went out to public hearing. This omission is inconsistent 

with EPA' 5 procedures for SIP revisions set forth at 40 C,F. R. § .51.1 02(dX2), which requires the 

availability of the entire plan for public inspection. The table of VOC emission limits is a 

significant part of the regUlation and, without the table available for public ill!>pection, 

meaningful public comment is ditlicult. ACHD must comply with state !Uld federal requirements 

for uotice and comment. 

To address the situation, EPA offered a "conditional approval" ofthe SIP submittal under 

Clean Air Act Section 11 O(kX4) if ACHD, within one year, amends and submits a revised 

Section 21 05.86 to EPA. 
Mr. Shs",n M. Garvin -2-	 July 16, 2014 

DEP and ACHD are confident that this commitment can be met for the following reasons: 

(I) 	The amount of technical work necessary for the measure 10 be adopted is minimal. The 

content of the table already exists in the CTG and must merely be placed into 

Article XXI, Section 2105.86. 

(2) 	 Adoption of the measure is not expected to be controversial because there are no relatt.-d 

regulated sources in Allegheny County. 

(3) 	 The regulation revision can be adopted at the county level, and reviewed b)' DEP and 

forwarded to EPA, in less than one year. 

DEP understands that this commitment will result in a conditional approval by EPA of the 

previously submitted CTO SIP revision 74 for Allegheny County. Upon EPA's approval of the 

SIP revision satisfying the rulemaking commitments, EPA's conditional appmval will become a 

full approval. 

Should you have questions or need additional information, pleac;e contact Joyce E. Epps, 

Director, Bureau of Air Quality, bye-mail atjccpps@pa.govorbytelephoneat 717.787.9702. 

You may also contact Jayme Oruham, Manager, ACHD Air Quality Program, bye-mail at 

jgraham@achd.net or by telephone at 412.578.8103. 

Sincerely, 

( . / o 

<. 	 (,'"I \ . (, \, E. Christopher Abruzzo 

Secretary 

Enclosures 
COUNTYOF ALLEGHENY 

RICH FITZGERALD 

June 26. 201.:1 

Ms, Joyce Erps, Director 

Bureau of Air Quality 

Department of linvironmcntal ProlL'Ction 

Rachel Carson 13uilding 

400 ~farket Street 

POBox 8468 

Harrisburg, PA 17105-8468 

Dear Ms. Epps: 

The purpose of this letter is to request your assistance with an action pending befbrc the U.S, 

Environmmtal Protection Agency (EPA) concerning the State Implementation Plan (SIP) 

Revision for the Allegheny County Health Dcpanmcnf s Fiberglass Boat ~fanut:,cluring 

laterials regulation. 

On November 15. 20U, the Pennsylvania Department of Fnvironmentaf Prott'Ction ,DEP) 

submitted II revision to Pennsylvania's State Implementation Plan ~S[P} pertaining to the 

udoption by the Allegheny CQUIlty Health Department (ACflD) in June 2013 of tour separate 

f't'gulations implementing Control Techniques Guidelines (eTGs) promulgated by the C.S. 

Environmental Protection Ag~nl.:y (EPA) in 200g lin Mi~elJane()\ls Metal and/or Plastic Parts 

Surface Coating Pr()Ccs.~es; Automobile and Light-Dllty Tmck ASs{'''1llbly Coalings: 

Miscellaneous Industrial Adhesives; and Fiberglass Boat Manufacturing Materials.. The revision 

is idmtified as revision No. 74 to the Attainment and Maintenance Plan t'Or ACHD's internal 

tracking. 

As a result (If its review. EPA has indicated that: 

(llln Section 2105.86. "Control (}f voe Emissions Irom Fiberglass Boat Manufacturing 

~Iatcrials." undcr Subsection 1.:. "Limitations.." Table 2105,86 (regarding average 

Immomer VOC content limit! is referen..:(.>U. but the table is n(.t incluu<:d til the submittal. 

(2) Given that ACIID subsequently reJ'('rtcd that the table had not been includt-"! as part of th.~ rr>llUl!ll,,'lr'+ th'l1 U·"'rtl ('Hit fn ruthl;,.,. hf"l1nnn th,,,, I"\m.~cihn t" ;¥I;1Vll"":;C'f<"'''''' \.,ith t:fla ."\0' 
To address the situation, FPA has offered a "conditional appnnal'" oithe SIP submittal under 

Clean Air Acl ;cclion 1 Hl{k)(-I) dllfing \\hkh lime ;\CHD wllult! \\Hnin one year amend and 

submit a rc\iscd Seclit'n 2105,1'1610 FI',\. 

With this understanding, Alleghcny County is rl'qucsting that ~ou seck the S.:cretary's 

concurrence and sil:lflaturc ill ,llcUcr to the EPA Region III AdministrJtor commiuing: ,\(,HD to 

revising Article XXI. Section 2105,86. which is before EPA li.)r activn pursuant to Section 

I H}(k) of the Clean Air Act. hy adding Table 2105J~6 (shown in th.; attachment) within one year 

trom the Federal Register publiclltion of tinaillorlce of o.:ondition.u approv,li \)f AcrID's C fG 

SIP 74, In tum, AUlD commits to revising Artide XXI Section ~I05,86 in it timely lashion thut 

will all()w DEI' adequntc time 10 revie\\ lInd submit the reviscd SIP to EPA within the one year 

time frame described abo,e. 

ACHD is eontident that Ihis commitment can be mct for the following reasons, 

(II The amount of technical work f1cc.:ssary for the measure to be adopted is minimal. The 

content ofthe ulblc already I.'xists in the eTG and must merely be placed into Article 

XXI. Sel;tion 2105,86. 

(2) Ad<;ption of the mert~\tre is nol expected to be contrmcrsiu/ Occause there arc no related 

regulated sources in Allegheny County, 

(3) Tbe regulation revision can be adopted a! the County leveL and revil.'wcd by PA DEP and 

flll'wurdt.-d 10 FPA in less Inan one year. 

A(,tID understands that this commitment will result in Ii conditional appro,al b) EPA ofthe 

previously submitted erG SIP revision No. 74 for Allegheny ('ounty, llpon EllA's approval of 

the SIP revision satisfying tbe rulemaking commilm('''l1ts. EPt\'s conditional appmvai to the 

Allegheny lJl)rtiun of the Pl'lnnsyhania SIP will becvmc a full approval, 

EPA request prompt action so thllt tinal !letion may \'Ie taken on the SIP revision, 

Thank ,ou 1'1r your llS!listanee in this mattl;!r, 
Table 2JO~.86 

)loDomcr voe Content Limitations for Open Molding [ledn lind (;,,1 Cout Operations 


APRlic.tion Method Weight A~'erage )fonomer VOC Content Limit 

(\leigh. pereent) 

Proouction Resin Atomized (spmy) 28 


Product!,," Resin I'onatnmi/cd .35 


Pigmented Gel Coat Any :V1cthod 33 


Clear Gel Coat An) :Vlcthod 48 


Tooling Resin Atomilt.'d 30 


Tooling Resin Nonatomix.ed 39 


Tooling Gel Coat AllY Method 4() 

3. 


Documentation of Public Hearing and Certifications 

Notice of Public Hearing 

Transmittals of hearing notice to EPA & PA DEP 

Proofof publication of notice of hearing 

Certification ofhearing 

Summary of comments and responses 

Certification of approval and adoption 
NOTICE OF PUBLIC HEARING 


FOR PROPOSED AMENDMENTS TO 


ALLEGHENY COUNTY HEALTH DEPARTMENT RULES AND REGULATIONS 


ARTICLE XXI, AIR POLLUTION CONTROL 


The Allegheny County Board ofHealth will hold a public hearing on Tuesday, October 

14,2014, at 10:00 AM, Building #7 First Floor Document Control Conference Room, 

Clack Health Center, 301 39th Street, Pittsburgh, PA 15201 to take testimony on a 

proposed modification to County Ordinance 16782, and Allegheny County Health 

Department Article XXI §2105.86, "Control ofVOC Emissions from Fiberglass Boat 

Manufacturing Materials." The proposed modification is to add Table 2105.86, 

"Monomer VOC Content Limitations for Open Molding Resin and Gel Coat Operations." 

The proposed modification will be incorporated as a revision to Allegheny 

County's portion of the Pennsylvania State Implementation Plan for the 

control of ozone. 

Copies ofthe proposed amendment may be examined beginning Friday, September 12, 

2014, at the Allegheny County Law Library, Room 921 City-County Building, Grant 

Street, Pittsburgh, PA 15219, from 8:30 AM to 5:00 PM; at the Allegheny County Health 

Department Document Control Room, Building 7, Clack Health Center, from 8:30 AM 

until 3 :30 PM Monday thm Friday; on the Allegheny County Health Department web 

site: www.achd.net; or by calling 412-578-8120 to request a mailed printed copy. 

Oral testimony must be pre-scheduled by calling 412-578-8120 no less than 24 hours in 

advance ofthe public hearing. Speakers will be limited to five minutes and should bring 

a written copy oftheir comments. 

The Board will accept written testimony beginning Friday, September 12,2014, and 

concluding Sunday, October 19,2014, by mail to: 

Allegheny County Health Department 

301 39th Street 

Pittsburgh, PA 15201-1891 

By email toagcomments@achd.net 

By Fax to 412-578-8144 
COUNTYOF ALLEGHENY 

RICH FITZGERALD 

CO',Jt'",T'f E'XECl:)l ~\,,,;f 

Ms. Diana Esher. Director 

Air Prole<:tion Division 

Rl!gionlII (3APOO) 

U.S, Environmental Protection Agency 

1650 Arch Street 

Philadelphia. PA 19103·2029 

Dear Ms. Esher: 

Enclosed is a Nolice of Public Hearing tbr a proposed revision to the AUeghcny County 

Health Department Rules and Regulations. Anicle XXI, Air Pollution Control and County 

Ordinance Num"'-'T 16782. regarding §2105.86. "Control ofVOC Emissions from Fi1~rglass 

Boat. Manutaclllring Materials." 

The proposed revision ,,,ill add Table 2105.86, "Monomer VOC Content Limitations tor 

Open ~1oldjng Resin and Gel Coat Operations," which was inadvertently omitted from Article 

XXI. when Section 1105.86 first bt..-came ef1i:ctivc June 8, 2013. 

J11C proposed regulation change will also he Sllbmittcd as a revision to Allegheny 

CouOly'S portion of the Pennsylvania State ImplerncntatillO Plan in order to satisfy lhe 

requirements ofthe EPA '5 proposed conditional approval of the revisions to the Pennsylvania 

SIP which uppear in the federal register of August 29, 1014 (79 FR 51515). It will be tracked 

internally by "CHI) as a supplement to SIP Revisioo 74. 

The public comment period begins September 12. 1014 and. concludes October 19,2014. 

The public hearing will be held October 14,2014. l'lltlr CllnUn..:nts are welcome. 

Sillccrch. 

C]Ci-i-;/icd~--. .Irt(mc Graham. \lunager 

Air {,lu<llily !)rngram 

cc: File 

Enclnsures 

• 	 Puhlic J{~aring Notice 

• 	 Proposed Article XX If 


SIP Supp1cmenttll Revision 74 


ALLEGHENY COUNTY HEALTH DEPARTMENT' AIR QUAUTY PROGRAM 
COUNTYOF ALLEGHENY

RICH FITZGERALD 

Septemocr 9, :W 14 

Ms. Joyce Epps. Director 

Bureau "f Air ()lIality 

Department of Emimmncntal Protcctivll 

Rachel Cars,.'" Building 

400 ~tarket Stft:t:t 

POBox 8468 

Ifarrisburg. PA 17105·8468 

Dear Ms, Epps: 

E:nek\sed is a Notice of Public Hearing for a proposed rcvisim'l to the Allegheny County Health 

Department Rules and Regulations. Article XXI. Air Pollution Control and Counly Ordinaoce Number 

16782. n:garding §2105,86. "Control ofV(X' Emissions from FiI)(:rglass noat Manufiltturing Materials." 

The proposed revision will add fable::: 105.86, "Monomer VOC Content Limitations fi)r Opcn 

Molding Resin and Gel Coat Operations:' "hieh was inadvertently omitted from Article XXI, \~hen 

S<:ctiOtl 2105,86 first became dTc!;tive June 8. 2013, 

The proposed rcgubuion change will also be submiucd as a revisioll to AHcll-ht:ny County's 

portion ufthe Pennsylvania State Implementation Plan in onh.~r to satisfy the requirements oflhe EPA's 

propu~'1i conditional approval of the revisions to the Pennsylvanin SIP which appear in the federal 

register of August 11). 2014 (79 FR 51515), It will be tracked illtcnlllll)' by ,"OfD as a ~upplement to SIP 

Revision 74. 

J'hc public comment period begins Septemher 12. :2014 and concludes Octo~r 19. :;014. The 

public hearing will be held October 14. 2014. Y"ur t{lmillents ar!: wckmne. 

Sinccrch. 

C~~/1o.-L~-

JZnc~Iham. Manager 

Air Quality Program 

cc; 	 IGrit Dalal 

StC\C Herler 

[nclosures 

• 	 Puhlic Ilearing NHlit:1! 


I'rol}<),ed Artide xxr 


Supplt'flwntal SIP RC1<ision 74 


ALLEGHENY COUNTY HEAL.TH DEPARTMENT' AIR QUALlrY PROGRAM 
Proof of Publication of Notice of Public Hearing 

'!\o. f<.:ml, 

Proof of Publication of Notice in Pittsburgh Post-Gazette 

\'mkr Act!'io 587. "ppn"..:u ~Iay 16.192<), PI. px.t, <lsla,t ilfll£nued hy .\..:1;';" -lO'll'fSI.:!lh:mhcr 29. 1951 

C'nun"I1\\C'alth "r i't'11l1'y!v;mia, ('!\lnT) of Alleglwny." .I;'. I::.br.t~fl)' '" ' , ..' l:>.:lll~ Jul, "~('m. d,p()~, <lnd ';lV', 'helt rhe 

p)\I~f,ufgh P'''I,{i~/,''t!C, a ne ..... '!'"p"r ef general circul;ui.m I'\lHbh~..J in thc City of I'itl,hurgh. Ci'umy .111d (\'mm.:>n\\cahh af"r;,."iJ, \\ j., 

""tdbli,'"," in 19\13 by till: l1l"rging of the Pm,hurgh 1'.",·(.u.:l1;1 and Sun· rd"graph and file PIII,burgh I'f<"~ .1lltllhc l'i!!'hul:}!.h l'o~l­

(iazcue :m.1 Sun-Telegraph ,,'a, c>labl"hcd l!l 191\l.' ,md tb.: Pittlobuigh !""I-Gazelle '''I., cSlabh_""d in 1'127 by th", merging "f the 

Pllbhurgh Galen;,: ."mhh,hcd In I'RI> and Ihe Pm,burgh PO,!, c...!ahli,h,.,j in 1114:. ,i!Ke "l'!l,h .LIe Ille ,uiJ I'lll,burgh p",!.(jalctt<: h;J, 

\;,;.:n ,c~ula!ly j"'l.lCd 11'1 'aiu Conn!) :lIId !ltal a "'I'Y Hf "llid pnm,'u l!(1!k<: or pu\'lliotion IS UHat'hed hcr~!'J ,':<.acII) J.< tI", ,am(' was 

printed ~mI puoh,hed III Ihe ..._._________!~£'!i.\ll___...... editions anJ ",'UC, \.1' the smJ P!u,burgh p,·,t-{i;velle J\ 

n"""part"l' "fltcm."!'<,1 cin:uj,l!I,m '\lIlhe ('!ie,wing d<ltes. ,·;z· 

10 orS~ptembtr. 2014 


Amant lilnhcr d~I"",e~ 'htlt hei,he b an agent for the I'D Puhlishing COI1lp;1I1), a corpl'faticlH Jild publish.:r or the t>ltbbur~h P,'st..(ia.lClte. 


Ih;II, 'os such ng~nl. amant is duly 3Ulh('t1leJ [,1 ""n(v [he t('reg,-.jn!; s!.llemenl under Nth. [hat Jllinnt is no! intcr~,tcd to til<: sub.!.:,t matler 


of the at"f': "ud nOlice I'f publi.:allo!1, and that all ilIIq!3!i"fl-S illlhe l()regoing ,s\.'lleme!1l '" It) IIInt:. pla.:e and chame!.."T ,)1' ll11hli'::lIielll "f" 


true, 

con Of :"OTICE 

s rATt:lm::'Ii'l 01<' ADVI>:RTISIN(; <:OSTS A~CTY ~~a:th Cept.-~la ified 

NAt:::Y )\.NN 'Ii!ET,"!':Y 

Ri?E~MONT ~~, PM 4 

(;rF'7t:E '~n~ ;-fl!~A~: ?ESQUP.CE: 

To PG Puhlishing C(llUp~ny 

Puhli~herts Receipt for Advertising Costs 

I'G PttlU.lSHING CO\IPANY. publisher of the Piu"hurgh Post-Gal.l,.'fh:, a I1c\vspapcr 

ofgenetal circulation, hereby acknowkdgcs receipt of the aforsaid adnmising and 

publication ~~(>sls and certifies th~llihe SlIme h:!\'c been tully paid. 

Olfkc PG I'uhlish,ng (b'l1)atl~, "C.nt'oral'Ol1. PI!t>lbhcr <If 

.l.\ iku]e"anl elr Ihe Alb"" p.1; ... bllrgh p(Y..t~G;'i7~"tt\.", a N(~\I.~p<!pt~r \lfOenentl Clrrul.1ti,,:,tl 

I'lfl ~H\}R()II.I'A 15222 

I'h,)Il<: 412-~t;.1-1 ,,1; By 

t h~'n'hJ c~ftdy d',l~ ~h~ tOft'~{\)H;t! I'" lbe Ilr~;;.i!Hi Prf~~t nf Puh-Ji,.~ri(;n .t:)t.i ro.: .. ci;1t f,1r th~ ,'J-'+t:fh~'nF .... ':.... tj "in tb; 

",.h}l;:'I.;1 u,,;1h'r uf ';',11d n.,tin~ 
SUPPLEMENTAL Rcvh.iun 74 

Supplemental SIP Suhmittal for 


Control of V()C Emissions from Fiberglass Bont Maouf:n:turing Materials 


CertiticAtion of lIcarin& 

Thomas Lattner deposes and ·mys that he is an Air Pollution Control F...ngillccr 111 of the 

Air Quality Program of the Allegheny County Health Department and hereby certil1es 

Ihat a Public Hearing was held on October 1...., 2014 on the proposed amendment to the 

County's portion of the Pennsylvania State Implementation Plan thut would revise Artkle 

XXI §2IOS.86, Control ofVOC Emissions from Fiberglass Boat Manufacturing 

Materi~ls fO add Table 2105.86; that the opportWlity for written comment.. wa... given in 

acconlance with the rt.'quiremcnts of 40 eFR 51.102; that notice of such hearing was 

given by ~lublicatioll in a m -wspapcr .. of general circulation on September 10.201 ....: and to 

the best of his knowledge, belief and understanding, such proceedings were in full 

compliance witb all applicable State and Federal laws. regulations, and other 

requirements. 

Thomas LaUner. 

Air Pollution Control Engineer lIT 

Air QlIulity Program 

Allegheny County Hcahh Department 
Summary of Comments and Responses 


for the 


Proposed Supplemental SIP Revision 74 


Regulation Change to Article XXI, §2105.86 to add Table 2105.86 


Public Comment Period from September 12 to October 19,2014 

October 14, 2014 Public Hearing 

1. 	 Comment: No comments were received. 

Commenter: 

Response: 
CERTIFICATION of APPROVAL and ADOPTION 

To the best of my knowledge, infonnation, and belie[", I the undersigned hereby eertif tlYl1 the 

amendments to §2105.86 ofAI1icie XXI, Rules and Regulation:'.l1fthe Allegheny ' unty He llh 

Depat1ment, Air Pollution Control, and Ordinance No. 167'X2 of the County 01" Allegheny, 

adopted by the Alleghcnv County Uoard of Health on ~ovember 5, _014, enacted b the 

Allegheny County Council on May 5, 2015 (Ordinance 14-IS-OR), approvcd by the ll 'gJl ' ny 

County Chief Executive on May 8, 2015 , and effective June 19, 2015, as a revision to the 

County':; Portion of the Pennsylvania St ate Implementation Plan I"or the Attainment nd 

Maintenance ,)1' the National Ambient Air Quality tandards. were duly and properly enacted a. 

pre cribed by the l.ocal Health Administration Law and the econd Clas unty Charter Law, 

and as such. are fully and lega ll enforceable by the Allegheny County Health Department and 

the County of Allegheny as provided for by the within authority. 

Vv\~a R-h Michc el . Parker 

A si tant Solicitor 

Allegheny County I Icalth Department 

COMl'vlONW AL TH OF PENNSYLV NIA) 

CO NTY OF ALLEGH E Ty ) =S=.S,,-. ___ 

On the (5 Y of IPbl.6t' . 2015, 


Michael A. Parker personally appeared before me, the undersigned authol;ty, satisractoril 


proven to me to be the person whose name appears above, and did in my presence execute the 


above certification for the purposes contained therein. 


WH -REf-ORE, I have hereunto set my hand and official seal the day of -IJllo/ ,2015. 

COMMONWEALTH OF PENN • VANtA 


Notariat Seal 


Henry Miller ro, Notary Public 


Ross Twp., Allegheny County 


My CommIssIOn EXpires Nov. 29, 2016 


PEHNSY\.VAHlA ASSOCIATl Of NOTAIUES