State of Vermont 

Department of Environmental Conservation 

November 22, 2006 

Robert W. Varney 

Regional Administrator 

U.S . EPA Region I 

1 Congress Street, Suite 1100 

Boston, MA 02114-2023 

AGENCY OFNATURAL RESOURCES 

~~C ~ 2 2006 

AIR QUAUTY PLAmvjj4u UNIT 

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SECRETARY'S OFFICE 

Center Building 

103 South Main Street 

Waterbury, VT 05671-301 

TEL 802-241-3600 

FAX 802-244-1102 

Re : Revisions to Vermont's SIP and SIP Narrative To Satisfy VOC RACT Requirements for 

Wood Furniture Manufacturing Operations 

Dear Regional Administrator Varney: 

The attached enclosures comprise submittal of a State Implementation Plan (SIP) revision to implement 

Reasonably Available Control Technology (RACT) for Volatile Organic Compound (VOC) emissions 

from the control techniques guideline (CTG) source category which covers wood furniture manufacturing 

operations . The wood furniture manufacturing CTG was published on May 20, 1996. Pursuant to section 

184 of the Clean Air Act as amended in 1990, Vermont is a part of the Ozone Transport Region and is 

thus required to implement RACT for this CTG source category. 

Under the authority of 10 V.S .A. § 558, Vermont adopted Vermont Air Pollution Control Regulation § 5-

253 .16 Wood Furniture Manufacturing. This regulation was adopted to satisfy the RACT requirement 

and to implement MACT requirements for the wood furniture manufacturing source category. This SIP 

submittal, however, is limited to those portions of § 5-253.16 that satisfy the RACT requirement. 

Accordingly, those portions of the regulation that apply only to the MACT requirements are lined out and 

are not being submitted for inclusion in Vermont's SIP at this time. 

This submittal contains : 

Enclosure 1 : Certification pursuant to 40 CFR Section 51 .102 with copies of published public notices 

announcing the date, time, and place of a public hearing on the proposed changes to Vermont Air 

Pollution Control Regulations and also proposed changes to Vermont's SIP Narrative. 

Enclosure 2: List of witnesses and commenters for the record, a summary of the rules hearing record 

comprised of questions and comments given orally at the hearing, and summaries of comments in writing 

received within the comment period, and Vermont's responses to the comments. 

Regional Offices - Barre/Essex Jct./Rutland/Springfield/St . Johnsbury 
Enclosure 3: Amendments to Vermont Air Pollution Control Regulations, copies of all the rulemaking documents required by Vermont's Administrative Procedure Act, and amendments to the Vermont SIP Narrative. In the case of the adopted regulation being submitted, only those portions of the regulation not lined-out are intended for inclusion in this SIP submittal, package. In the case of the SIP Narrative 

material, the changes and amendments, whi6h a,re ~underlined, have been incorporated to existing pages 63 to 71 of the Narrative document currently approved by EPA. The attached revised pages 63 to 71 are 

intended to completely replace the existing pages 63 to 71 of the SIP Narrative. 

This submittal package includes all the documentation for EPA to consider these SIP revisions complete. I trust that EPA will find that this submittal fulfills Vermont's obligations under the Clean Air Act as amended in 1990 for adoption of Wood Furniture Manufacturing RACT controls required of the Ozone Transport Region states to address ozone non-attainment in the Region. Should you have questions about this submittal, please contact Richard Valentinetti, Director of the Air Pollution Control Division . 

Canute Dalmasse, Acting Secretary 

Agency of Natural Resources