State ofVermont

Department ofEnvironmental 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

FV Y SECRETARY'S OFFICE Center Building 103 South Main Street Waterbury, VT 05671-301 TEL 802-241-3600 FAX802-244-1102

Re: Revisions to Vermont's SIP and SIP Narrative To Satisfy VOCRACT 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 fromthe control techniques guideline (CTG) source category which covers wood furniture manufacturing operations. The wood furniture manufacturing CTGwas published on May 20, 1996. Pursuant to section 184of the CleanAir Act as amended in 1990, Vermont is a part of the Ozone Transport Region and is thus required to implement RACT for this CTGsource category. Under the authority of 10V.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 CFRSection 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 ofwitnesses and commenters for the record, a summary of the rules hearing record comprised ofquestions 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/EssexJct./Rutland/Springfield/St . JohnsburyEnclosure 3: Amendments to Vermont Air Pollution Control Regulations, copies ofall 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, onlythose 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 ofthe Narrative document currently approved by EPA . The attached revised pages 63 to 71 are intended to completely replace the existing pages 63 to 71 ofthe SIPNarrative. This submittal package includes all the documentation for EPA to consider these SIP revisions complete. I trust that EPAwill find that this submittal fulfills Vermont's obligations under the CleanAir Act as amended in 1990for adoption ofWood Furniture Manufacturing RACT controls required ofthe 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