INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers and OurEnvironment.

Michael R. Pence Governor



### Susan Hedman Regional Administrator U.S. EPA, Region 5 77 West Jackson Boulevard Chicago, Illinois 60604

DearMs. Hedman: 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

July 17, 2015 Thomas W. Easterly Commissioner



### Re: State Implementation Plan Submittal for IndianaRegarding 326 lAC 8-12-4, Shipbuilding Antifoulant Coatings (LSA #

### 14-441)

Pursuantto Section 110 ofthe Clean Air Act and Title 13 ofthe Indiana Code, the IndianaDepruiment ofEnvironmental Management (IDEM) submits an amendment to the Indiana state implementationplan (SIP). This amendment consists ofrevisions to 326 lAC 8-12- 4 accomplished through one rulemaking. IDEM requests thatthe United States Environmental Protection Agency (U.S. EPA) approve 326 lAC 8-12-4. This rulemaking amends the volatile organic compounds (VOC) limit for antifoulant coatings applicable to owners or operators ofshipbuilding or ship repair facilities located in ·Clark, Floyd, Lake, or Potier counties at 326 lAC 8-12-4. The revised VOC limit of3.33 pounds

per gallon is consistent withthe limit inthe Control Techniques Guideline (CTG) (August 27, 1996, Federal Register, 61 FR44053) that U.S. EPA issued for determining reasonable available control technology (RACT) for shipbuilding and ship repair operations located in ozone nonattainment areas and the final National Emission Standards for Hazardous Air Pollutants (NESHAP) for Shipbuilding and Ship Repair, 40 CFR 63, Subprui II. This SIP revision relies on offsets generated bythe Architectural and Industrial Maintenance (AIM) coatings rule adopted at 326 lAC 8-14. Indiana's AIM coatings rule goes above and beyondthe federal AIM rule by adopting a rule that is similar to the Ozone Transpmi Commission (OTC) model rule. According to a 2006 Lake Michigan Air Directors Consortium (LADCO) white paper, the OTC model rule provides a 31% to 48.4% (depending onthe AIM coatings category) reduction inVOC emissions compared to uncontrolled 2002 base case emissions while the federal AIMrule alone provides a 20% reduction comparedto the base case. The Indiana AIM rule was approved into the SIP on August 30, 2012 (77 FR 52606). Indiana was not required to adopt an AIM coatings rule but did so as a multi-state effort to help reduce ozone levels at the regional level. Indiana did not adopt the AIM rule to comply with any Indiana SIP planning requirements and has not taken credit for it in air quality plans. Ithas not been included inmaintenance year horizons or rate offurther progress (RFP) inventories. Therefore, these SIP approved AIM limits canbe used as offsets for other purposes, such as this

An Equal Opportunity Employer 

# 0 @ RecycledPaper AState**that~**Ms. Susan Hedman Page 2 of2 

### SIP revision. This SIP revision does not account for all ofthe offsets generated by the AIM rule and Indiana will also be using a portion ofthe AIM offsets in a corresponding SIP revision, the Stage II Vapor Recovery Systems SIP revision submitted on April27, 2015. Based onthe use of offsets, IDEM has determined that there is no impact onthe ozone NAAQS. On October 23, 2014, IDEM submitted a Commissioner's Order for SIP approval in regards to a site specific RACTpetition for Jeffboat LLC. This rulemaking addresses the same VOC limit included inthe site specific RACT petition. The rulemaking makes the revised limit for antifoulant coatings applicable to all sources potentially subject to the rule, notjustJeffboat LLC, although, Jeffboat is the only known source. IDEM requests that the SIP revision address boththe site specific RACTpetition and the rulemaking. This submittal consists ofone (1) hard copy ofthe required documentation. An 

### electronic version ofthe submittal inPDF format that is identical to the hard copy has been sent to Chris Panos at the U.S. EPA Region 5 office. In order to assist with your review ofthis state implementationplan submission, a list ofsupporting documents is attached. Throughoutthe development ofthis amendment to existingrule 326 lAC 8-12-4, staffof the Office ofAir Quality worked closely with your staffto ensure that any potential problems that might exist with this requested state implementationplanrevision would be resolved. I request thatU.S. EPA approve this modification ofIndiana's SIP. Ifyou have any questions regcu.·ding this submittal, please contact Christine Pedersen, Rule Development Section Chief,

. Office ofLegal Counsel at (317) 233-5684.

KB/sb Attachments: Supporting Documents Sincerely,

# ~~ Keith Baugues Assistant Commissioner Office ofAir Quality

cc: John Mooney, U.S. EPA Region V (no enclosures) PamelaBlakley, U.S. EPA Region V (no enclosures) Doug Aburano, U.S. EPARegion V (no enclosures) Steve Rosenthal, U.S. EPA Region V (no enclosures) Christine Pedersen, IDEM (no enclosures) SIP file

### Supporting Documents

Attachment A: Administrative Checklist (40 CFR 51, Appenqix V) Attachment B: Final Rule. LSA Document#14-441(F) as posted inthe IndianaRegister on June 17, 2015 (DIN: 20150617-IR-326140441FRA) Attachment C: Signature Page Attachment D: Findings and Determination ofthe Commissioner Pursuant to IC 13-14-9-7 and Second Notice ofPublic Comment Period, including the Notice ofPublic Hearing, as published inthe Indiana Register on October 29, 2014 (DIN: 20141029-IR-326140441FNA) Attachment E: Cmiificates ofWeb Publication AttachmentF: Transcript ofFirst Public Hearing held on Janumy 14, 2015. Attachment G: Proposed Rule, including theNotice ofPublic Hearing, as published in the Indiana Register onFebruary 4, 2015 (DIN: 20150204-IR-326140441PRA) Attachment H: Transcript ofSecond Public Hearing held onMarch 11, 2015 Attachment I: Technical SuppmiDocumentationADMINISTRATIVE CHECKLIST (40 CFR 51, Appendix V) 1. The submittal is accompanied by a formal letter ofsubmittal from the governor orhis designee. 2. Evidence that the State has adopted the planinthe State code or body ofregulations; or issued the permit, order, consent agreement ("document"); in final form.

a. Date ofadoption or final issuance: b. The effective date ofthe plan, ifdifferent from the adoption/issuance date. 

### 3. Evidence thatthe State has the necessary legal authority under state lawto adopt and implement the plan. 4. A copy ofthe actual regulation or document submitted for approval and incorporation by reference into the plan, including the following:

a. Indication ofthe changes made to the existing approved plan, where applicable. b. The submittal shall be a copy ofthe official State regulation or document signed, stamped, dated by the appropriate state official indicating that it is fully enforceable bythe State. Effective date shall be stated inthe document itself. 5. Evidence that the State followed all ofthe procedural requirements ofthe State's laws and constitution in conducting and completing the adoption/issuance ofthe plan. Enclosed

Attachment C

March 11, 2015 June 21, 2015 (filed May 22, 2015)

IC 13-14-8

Attachment B

Attachment C

6. Evidence that public notice was given, including date of Attachments D, E, and G proofofpublication. _x_Notice ofFirst Public Hearing and Certificates ofWeb Publication _· x_Notice ofSecond Public Hearing and Certificates ofWeb Publication 7. Certificationthatpublic hearings were held in accordance with information provided inpublic hearing notice. _x_Transcript from First Public Hearing _x_Transcript from Second Public Hearing 8. Compilation ofpublic comments and State's response. _x_Proposed Rule 9. Technical Support Document (ifsource specific change). Attachments F and H

Attachment G

Attachment IIndiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION Final Rule LSA Document #14-441 (F) DIGEST Amends 326 lAC 8-12-4 concerning antifoulant coatings used at shipbuilding and ship repair facilities. Effective 30 days after filing with the Publisher. HISTORY Findings and Determination ofthe Commissioner Pursuant to IC 13-14-9-7 and Second Notice of Comment Period: October 29, 2014, Indiana Register (DIN: 20141 029-IR-326140441 FDA). Notice of First Hearing: October 29, 2014, Indiana Register (DIN: 20141029-IR-326140441PHA). Date of First Hearing: January 14, 2015. Proposed Rule: February 4, 2015, Indiana Register (DIN: 20150204-IR-326140441PRA). Notice of Second Hearing: February 4, 2015, Indiana Register (DIN: 20150204-IR-326140441 PHA). Date of Second Hearing: March 11, 2015. 326 lAC 8-12-4 SECTION 1. 3261AC 8-12-41S AMENDED TO READ AS FOLLOWS: 326 lAC 8-12-4 Volatile organic compound emissions limiting requirements Authority: IC 13-14-8; IC 13-17-3-4 Affected: IC 13-12 Sec. 4. (a) On and after May 1, 1996, The owner or operator of a shipbuilding or ship repair facility subject to this rule shall comply with the following VOC emissions limiting requirements: (1) Provisions applicable to specialty coatings are as follows:

(A) Special marking coatings shall, not exceed a VOC content offour and eight-hundredths (4.08) pounds per gallon. ,. " (B) Heat resistant and high-gloss coatings shall not exceed a VOC content ofthree and**fifty~hundredths** (3.50) pounds per gallon. (C) High-temperature coatings shall not exceed a VOC content offour and seventeen-hundredths (4.17) pounds per gallon. (D) Antifoulant coatings shall not exceed a VOC content ofthree and thirty-three hundredths (3.33) pounds per gallon. fG1 (E) Weld-through (shop) preconstruction primers shall comply with subdivisions (3) through (5). 

### fE1 (F) Any other specialty coating shall not exceed a VOC content oftwo and eighty-three hundredths (2.83) pounds per gallon. (2) During application of any general use coating, VOC emissions shall be limited as follows:

(A) The VOC content of any general use coating shall not exceed two and eighty-three hundredths (2.83) pounds per gallon, as applied. (B) From May 1 through September 30, no thinner shall be added to any general use coating. (3) During application of any weld-through (shop) preconstruction primer, VOC emissions shall be limited throughout the year as follows: (A) Waterbased weld-through (shop) preconstruction primer shall be used. (B) The VOC content of weld-through (shop) preconstruction primer, as applied, shall not exceed zero (0). (C) No cleaning material shall be used in the primer application facility. (D) No thinner shall be added to the weld-through (shop) preconstruction primer. (4) Ifthe owner or operator of a shipbuilding or ship repair facility determines that a waterbased weld-through (shop) preconstruction primer can no longer be used due to an operational, performance, or availability constraint associated with the waterbased weld-through (shop) preconstruction primer, the source shall do the following: (A) Notify the department within seven (7) days of discontinuing use ofthe waterbased weld-through (shop) preconstruction primer. (B) Submit to the department for approval a plan for an alternative control within sixty (60) days of discontinuance. The alternative control shall consist of one (1) ofthe following:

(i) A waterbased weld-through (shop) preconstruction primer.

Date: Jun 17,2015 3:02:21 PM EDT DIN: 20150617-IR-326140441FRA Page 1Indiana Register (ii) A control system with a minimum overall VOC emissions reduction efficiency of ninety-five percent (95%) that is subject to each ofthe following requirements:

(AA) The operation, maintenance, and testing requirements of 326 lAC 8-7-9. (BB) The monitoring, record keeping, and reporting requirements of 326 lAC 8-7-1 0. (C) Install the alternative control within nine (9) months of approval by the department ofthe plan required in clause (B). (5) During the time between the date when the owner or operator ofthe shipbuilding or ship repair facility discontinues the use ofthe waterbased preconstruction primer and the date when the alternative control is installed, the weld-through (shop) preconstruction primer used by the owner or operator of such shipbuilding or ship repair facility shall not exceed a VOC content of five and sixty-five hundredths (5.65) pounds per gallon or the VOC content for weld-through (shop) preconstruction primer prescribed by the U.S. eP/\ in a final regulation establishing National emissions Emission Standards for Shipbuilding and Ship Repair (Surface Coating), 40 CFR 63, Subpart II, whichever is lower. (b) On and after May 1, 1996, A source subject to this rule shall comply with the following work practice standards: (1) Cleaning accessories, such as, but not limited to, paper, cloth, and rags that have been used for cleaning surfaces and equipment and that contain cleaning materials shall be stored in normally closed gasket sealed containers. (2) VOC-containing solvents and coatings shall be stored in normally closed sealed containers prior to use. Spent VOC-containing solvents and coatings shall be stored in normally closed gasket sealed containers. (3) Cleaning materials for cleaning spray equipment, including paint lines, shall not be used unless the equipment for collecting the cleaning materials and minimizing its evaporation to the atmosphere is used. (4) All handling and transfer of VOC-containing materials to and from containers, tanks, vats, drums, and piping systems shall be conducted in a manner that minimizes drips and spills, and any drips and spills shall be cleaned up promptly. (5) All containers, tanks, vats, drums, and piping systems shall be free of cracks, holes, and other defects and must be closed unless materials are being added to or removed from them. (c) The owner or operator of sources subject to this rule shall comply with the following training requirements: (1) On or before January 1, 1996, The owner or operator shall develop a written worker training program. The training program shall be included in'the compliance plan required to be submitted to the department for review by section 7(b)(1) ofthis rule.

·(2) On or before May 1, 1996, All workers, including contractors, shall have completed a training program if they engage in any ofthe activities listed in subdivision (3). (3) The training program may include training provided by the manufacturer or supplier of coatings, cleaning materials, or the application equipment thereof, and shall include written procedures, hands-on demonstration, as appropriate, and certification by the trainer ofthe trainee's ability to perform the task, on the following activities: (A) Identification of appropriate coatings or cleaning materials. (B) Preparation of coatings or cleaning materials according to coating or cleaning material manufacturer, distributor, or owner or operator's recommendations. (C) Application of coatings or cleaning materials, or organic solvents using techniques that minimize their usage. (D) Procedures to clean spray guns to minimize evaporation of organic solvents to the atmosphere. (E) Work practice standards established in subsection (b). (F) Procedures to gather, record, monitor, and report data in accordance with section 7 of this rule. (4) Beginning in 1997, The owner or operator shall provide annual refresher training prior to May 1 to any worker performing one (1) or more ofthe activities listed in subdivision (3). Such training shall be appropriate to the job responsibilities ofthe worker. (5) Any worker may perform one (1) or more activities listed in subdivision (3), for not more than one hundred eighty (180) days, notwithstanding the requirement of subdivision (2), provided:

(A) such untrained worker works under the supervision of a worker who meets the training requirements of subdivision (2); and (B) the owner or operator keeps records of:

(i) the date the worker was assigned to the activity; (ii) the date training was completed; and (iii) the name ofthe worker providing the supervision. (6) The owner or operator shall keep records ofthe training program. The records shall consist ofthe following:

Date: Jun 17,2015 3:02:21PM EDT DIN: 20150617-IR-326140441FRA Page 2Indiana Register (A) The date training was completed. (B) A list of workers by name and worker activities listed in subdivision (3) in which each worker has been trained. (C) A statement signed by the person providing the training certifying that the worker completed training and is proficient in the activities listed in subdivision (3) in which the worker will be engaged. (Air Pollution Control Division; 3261AC B-12-4: filedApr 1, 1996, 10:00 a.m.: 191R 1753; filed Jun 15, 2001, 12:0B p.m.: 241R 3613; filed May 22, 2015, 3:14p.m.: 20150617-IR-326140441FRA)

LSA Document #14-441(F) Proposed Rule: 20150204-IR-326140441PRA Hearing Held: March 11, 2015 ApprovedbyAttorney General: May 15, 2015 Approvedby Governor: May20, 2015 Filed with Publisher: May 22, 2015, 3:14p.m. Documents Incorporated by Reference: None Received by Publisher Small Business Regulatory Coordinator: Jessica Faust-Hamblin, IGCN 1225, 100 North Senate Avenue Indianapolis, IN 46204-2251, (317) 232-B172 or (BOO) 9BB-7901, ctap@idem.in.gov Small Business Assistance Program Ombudsman: Steven N. Howell, IGCN 1301, 100 North Senate Avenue, Indianapolis, IN 46204-2251, (317) 232-B5B7 or (BOO) 451-6027, snhowell@idem.in.gov Posted: 06/17/2015 by Legislative Services Agency An html version ofthis document.

Date: Jun 17,2015 3:02:21PM EDT DIN: 20150617-IR-326140441FRA Page 3

# Rule Signature Page

Rule#: LSA Document# 14-441(F) Environmental Rules Board Shipbuilding and Ship Repair Agency: Subject: ADOPTED:

# ~~~ Beverly

### J. Gard ., . By: Chairperson, Environmental Rules Board

APPROVED:

# n~f}·**~:...--...,-** Governor, State ofIndiana

ACCEPTED FORFILING:
By: TI1LE 326 AIRPOLLUTION CONTROL DIVISION LSA Docmnent #14-44l(FR) Filed with Publisher: May 22,2015, 3:14p.m. By: Kks· Date 

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# I**Date:~r**Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION FINDINGS AND DETERMINATION OF THE COMMISSIONER PURSUANT TO IC 13-14-9-7 AND SECOND NOTICE OF COMMENT PERIOD LSA Document #14-441 SHIPBUILDING AND SHIP REPAIR ANTIFOULANT COATINGS PURPOSE OF NOTICE The Indiana Department of Environmental Management (IDEM) has developed draft rule language for amendments to 326 lAC 8-12 concerning antifoulant coatings used at shipbuilding and ship repair facilities. The purpose ofthis notice is to seek public comment on the draft rule, including suggestions for specific language to be included in the rule. IDEM seeks comment on the affected citations listed and any other provisions of Title 326 that may be affected by this rulemaking. CITATIONS AFFECTED: 326 lAC 8-12-4. AUTHORITY: IC 13-14-18; IC 13-17-3. STATUTORY REQUIREMENTS IC 13-14-9-7 recognizes that under certain circumstances it may be appropriate to reduce the number of public comment periods routinely provided. In cases where the commissioner determines that the rulemaking policy alternatives available to IDEM are so limited that the first notice of public comment period would provide no substantial benefit to the environment or persons to be regulated or otherwise affected by the proposed rule, IDEM may forgo this comment period and proceed directly to the notice of second public comment period. If the commissioner makes the determination of limited rulemaking policy alternatives required by IC 13-14-9- 

# z. the commissioner shall prepare written findings and include them in the second notice of public comment period published in the Indiana Register. This document constitutes the commissioner's written findings pursuant to IC 13-14-9-7. The statute provides for this shortened rulemaking process if the commissioner determines that "the rulemaking policy alternatives available to the department are so limited that the public notice and comment period under [IC 13-14-9-3]

... would provide no substantial benefit to: (1) the environment; or (2) persons to be regulated or otherwise affected by the proposed rule.". BACKGROUND IDEM regulates volatile organic compound (VOC) emissions from surface coating operations at shipbuilding and ship repair facilities at 326 lAC 8-12. The shipbuilding and ship repair rule was adopted in 1995 to comply with Section 182(b)(1) ofthe Clean Air Act that required ozone nonattainment areas classified as moderate or above to develop plans to reduce the areas' VOC emissions by at least 15% by November 15, 1996. Reduction plans were prepared for Clark, Floyd, Lake, and Porter counties. These plans relied on a variety of mobile, stationary, and area source controls, including control ofVOC from shipbuilding and ship repair surface coating operations. The United States Environmental Protection Agency (U.S. EPA) was working on the Control Technique Guideline (CTG) for this source category but had not issued the CTG by the time IDEM needed to proceed with rulemaking to meet Clean Air Act deadlines. U.S. EPA had also proposed a National Emission Standard for Hazardous Air Pollutants (NESHAP) for shipbuilding and ship repair. IDEM developed 326 lAC 8-12 to be consistent with the proposed NESHAP as much as possible. Jeffboat LLC, located in Jeffersonville (Clark County) is the primary source regulated by 326 lAC 8-12. Jeffboat LLC recently made a request to IDEM to amend the VOC content limit for antifoulant coatings. Section 4(a)(1)(E) of 326 lAC 8-12 indicates that specialty coatings not specifically listed shall not exceed a VOC content of 2.83 pounds per gallon. Antifoulant coatings are not specifically listed and are subject to the 2.83 pounds per gallon limit. The antifoulant coating that Jeffboat LLC was using with a VOC content limit of 2.83 pounds per gallon was discontinued by the supplier and is no longer available. There are two antifoulant coatings remaining on the market that meet the more stringent Indiana requirements in 326 lAC 8-12-4(a)(1)(E). The first is specifically designed for yachts and does not have the same ablative properties that are required in barge manufacturing. The second costs three times more than the other available antifoulant coatings, putting Jeffboat LLC, and potentially any other source subject to 326 lAC 8-12, at a severe economic disadvantage to facilities in other states that can purchase the cheaper antifoulant coatings that meet the VOC content limit in the NESHAP. IDEM is proposing an antifoulant VOC content limit of 3.33 pounds per gallon. This is consistent with the limit in the final NESHAP for Shipbuilding and Ship Repair, 40 CFR 63, Subpart II, Table 2 and the CTG (August 27, 1996, Federal Register, 61 FR 44053) that U.S. EPA issued for the control of VOC emissions to assist states in

Date: Jun 19,201510:55:11AM EDT DIN: 20141029-IR-326140441FDA Page 1Indiana Register analyzing and determining reasonable available control technology (RACT) for shipbuilding and ship repair operations located in ozone nonattainment areas. IDEM is not aware of any other state RACT rules with more stringent VOC limits than the 3.33 pounds per gallon VOC content limit for antifoulant coatings. The current limit in 3261AC 8-12-4 is part ofthe Indiana state implementation plan (SIP) and IDEM will submit this rulemaking to U.S. EPA for SIP approval once it is effective. IDEM will provide a Section 110(1) Clean Air Act demonstration for antibacksliding for SIP approval and will rely on reductions in the state architectural and industrial maintenance (AIM) rule at 326 lAC 8-14 for the antibacksliding demonstration. IDEM is using a Section 7 notice for this rulemaking because the options for the amendment are limited and it is the only amendment IDEM is proposing for this rulemaking. The proposed limit is consistent with federal law. IC 13-14-9-41dentification of Restrictions and Requirements Not Imposed under Federal Law No element ofthe draft rule imposes either a restriction or a requirement on persons to whom the draft rule applies that is not imposed under federal law. Potential Fiscal Impact This rulemaking will save the affected source money since the source will not have to switch to a higher cost coating and will not lose customers to competitors that can respond to a customer's request to use a specific manufacturer coating system to coat the barge. IfJeffboat LLC cannot offer the same options as other manufacturers in other states, they may have to decline business or send the barge to an outside independent shipyard in another state, which could substantially increase cost to Jeffboat LLC or negatively impact their ability to give timely service to customers. Coating suppliers are normally awarded the whole vessel for their paint system, and therefore, do not go to the expense to test antifoulants with other supplier's epoxy, and do not warranty their coating system with other supplier's antifoulants. Public Participation and Work Group Information No work group is planned for the rulemaking. Ifyou feel that a work group or other informal discussion on the rule is appropriate, please contact Susan Bem, Rules Development Branch, Office of Legal Counsel at (317) 233-5697 or (800) 451-6027 (in Indiana). Small Business Assistance Information IDEM established a compliance and technical assistance program (CTAP) under IC 13-28-3. The program provides assistance to small businesses and information regarding compliance with environmental regulations. In accordance with IC 13-28-3 and IC 13-28-5, there is a small business assistance program ombudsman to provide a point of contact for small businesses affected by environmental regulations. Information on the CTAP program, the monthly CTAP newsletter, and other resources available can be found at: www.in.gov/idem/ctap For purposes of IC 4-22-2-28.1, small businesses affected by this rulemaking may contact the Small Business Regulatory Coordinator: Jessica Faust-Hamblin IDEM Small Business Regulatory Coordinator IGCN 1225 100 North Senate Avenue Indianapolis, IN 46204-2251 (317) 232-8172 or (800) 988-7901 ctap@idem.in.gov For purposes of IC 4-22-2-28.1, the Small Business Ombudsman designated by IC 4-4-35-8 is:

Erik Scheub Office of Small Business and Entrepreneurship One North Capitol, Suite 600 Indianapolis, IN 46204 (317) 232-5679 ombudsman@osbe.in .gov Resources available to regulated entities through the small business ombudsman include the ombudsman's duties stated in IC 4-4-35-8, specifically IC 4-4-35-8(9), investigating and attempting to resolve any matter regarding compliance by a small business with a law, rule, or policy administered by a state agency, either as a party to a proceeding or as a mediator. The Small Business Assistance Program Ombudsman is: Steven N. Howell IDEM Small Business Assistance Program Ombudsman IGCN 1301 100 North Senate Avenue Indianapolis, IN 46204-2251 (317) 232-8587 or (800) 451-6027 snhowell@idem.in.gov

Date: Jun 19,201510:55:11AM EDT DIN: 20141029-IR-326140441FDA Page 2Indiana Register FINDINGS The commissioner of IDEM has prepared written findings regarding rulemaking on a revised VOC content limit for antifoulant coatings at 326 lAC 8-12-4. These findings are prepared under IC 13-14-9-7 and are as follows: (1) The options for a revised VOC limit for antifoulant coatings are very limited. If the revised limit is not consistent with RACT, U.S. EPA will not approve the new limit. (2) I have determined that under the specific circumstances pertaining to this rule, the rulemaking policy alternatives are so limited that the public notice and comment period provided in the notice of first public comment period would provide no substantial benefit to the environment or to persons to be regulated or otherwise affected by the rule. (3) The draft rule is hereby incorporated into these findings. Thomas W. Easterly Commissioner Indiana Department of Environmental Management REQUEST FOR PUBLIC COMMENTS This notice requests the submission of comments on the draft rule language, including suggestions for specific revisions to language to be contained in the draft rule. Comments may be submitted in one ofthe following ways: (1) By mail or common carrier to the following address:

LSA Document #14-441 Shipbuilding Antifoulant Coatings Susan Bem Rules Development Branch Office of Legal Counsel Indiana Department of Environmental Management Indiana Government Center North 100 North Senate Avenue Indianapolis, IN 46204-2251 (2) By facsimile to (317) 233-5970. Please confirm the timely receipt of your faxed comments by calling the Rules Development Branch at (317) 232-8922. (3) By electronic mail to sbem@idem.in.gov. To confirm timely delivery of submitted comments, please request a document receipt when sending the electronic mail. PLEASE NOTE: Electronic mail comments will NOT be considered part ofthe official written comment period unless they are sent to the address indicated in this notice. (4) Hand delivered to the receptionist on duty at the thirteenth floor reception desk, Office of Legal Counsel, Indiana Government Center North, 100 North Senate Avenue, Indianapolis, Indiana. Regardless ofthe delivery method used, to properly identify each comment with the rulemaking action it is intended to address, each comment document must clearly specify the LSA document number ofthe rulemaking. COMMENT PERIOD DEADLINE All comments must be postmarked, faxed, or time stamped not later than December 1, 2014. Hand-delivered comments must be delivered to the appropriate office by 4:45 p.m. on the above-listed deadline date. Additional information regarding this action may be obtained from Susan Bem, Rules Development Branch, Office of Legal Counsel) (317) 233-5697 or (800) 451-6027 (in Indiana). DRAFT RULE SECTION 1. 326 lAC 8-12-4 IS AMENDED TO READ AS FOLLOWS: 326 lAC 8-12-4 Volatile organic compound emissions limiting requirements Authority: IC 13-14-8; IC 13-17-3-4 Affected: IC 13-12 Sec. 4. (a) On and after May 1, 1996, the owner or operator of a shipbuilding or ship repair facility subject to this rule shall comply with the following VOC emissions limiting requirements: (1) Provisions applicable to specialty coatings are as follows:

(A) Special marking coatings shall not exceed a VOC content offour and eight-hundredths (4.08) pounds per gallon. (B) Heat resistant and high-gloss coatings shall not exceed a VOC content ofthree and fifty-hundredths

Date: Jun 19,201510:55:11AM EDT DIN: 20141029-IR-326140441FDA Page 3Indiana Register (3.50) pounds per gallon. (C) High-temperature coatings shall not exceed a VOC content offour and seventeen-hundredths (4.17) pounds per gallon. (D) Antifoulant coatings shall not exceed a VOC content ofthree and thirty-three hundredths (3.33) pounds per gallon. f91 (E) Weld-through (shop) preconstruction primers shall comply with subdivisions {3) through (5). 

### fE1 (F) Any other specialty coating shall not exceed a VOC content oftwo and eighty-three hundredths (2.83) pounds per gallon. (2) During application of any general use coating, VOC emissions shall be limited as follows:

(A) The VOC content of any general use coating shall not exceed two and eighty-three hundredths (2.83) pounds per gallon, as applied. (B) From May 1 through September 30, no thinner shall be added to any general use coating. (3) During application of any weld-through (shop) preconstruction primer, VOC emissions shall be limited throughout the year as follows: (A) Waterbased weld-through (shop) preconstruction primer shall be used. (B) The VOC content of weld-through (shop) preconstruction primer, as applied, shall not exceed zero (0). (C) No cleaning material shall be used in the primer application facility. (D) No thinner shall be added to the weld-through (shop) preconstruction primer. (4) If the owner or operator of a shipbuilding or ship repair facility determines that a waterbased weld-through (shop) preconstruction primer can no longer be used due to an operational, performance, or availability constraint associated with the waterbased weld-through (shop) preconstruction primer, the source shall do the following: (A) Notify the department within seven (7) days of discontinuing use of the waterbased weld-through (shop) preconstruction primer. (B) Submit to the department for approval a plan for an alternative control within sixty (60) days of discontinuance. The alternative control shall consist of one (1) ofthe following:

(i) A waterbased weld-through (shop) preconstruction primer. (ii) A control system with a minimum overall VOC emissions reduction efficiency of ninety-five percent (95%) that is subject to each ofthe following requirements:

(AA) The operation, maintenance, and testing requirements of 326 lAC 8-7-9. (BB) The monitoring, record keeping, and reporting requirements of 326 lAC 8-7-10. (C) Install the alternative control within nine (9) months of approval by the department ofthe plan required in clause (B). (5) During the time between the date when the owner or operator ofthe shipbuilding or ship repair facility · discontinues the use ofthe waterbased preconstruction primer and the date when the alternative control is installed, the weld-through (shop) preconstruction primer used by the owner or operator of such shipbuilding or ship repair facility shall not exceed a VOC content of five and sixty-five hundredths (5.65) pounds per gallon or the VOC content for weld-through (shop) preconstruction primer prescribed by the U.S. EP/\ in a final regulation establishing National Emissions Emission Standards for Shipbuilding and Ship Repair (Surface Coating), 40 CFR 63, Subpart II, whichever is lower. (b) On and after May 1, 1996, a source subject to this rule shall comply with the following work practice standards: (1) Cleaning accessories, such as, but not limited to, paper, cloth, and rags that have been used for cleaning surfaces and equipment and that contain cleaning materials shall be stored in normally closed gasket sealed containers. (2) VOC-containing solvents and coatings shall be stored in normally closed sealed containers prior to use. Spent VOC-containing solvents and coatings shall be stored in normally closed gasket sealed containers. (3) Cleaning materials for cleaning spray equipment, including paint lines, shall not be used unless the equipment for collecting the cleaning materials and minimizing its evaporation to the atmosphere is used. (4) All handling and transfer of VOC-containing materials to and from containers, tanks, vats, drums, and piping systems shall be conducted in a manner that minimizes drips and spills, and any drips and spills shall be cleaned up promptly. (5) All containers, tanks, vats, drums, and piping systems shall be free of cracks, holes, and other defects and must be closed unless materials are being added to or removed from them. (c) The owner or operator of sources subject to this rule shall comply with the following training requirements: (1) On or before January 1, 1996, the owner or operator shall develop a written worker training program. The training program shall be included in the compliance plan required to be submitted to the department for review by section 7(b)(1) ofthis rule.

Date: Jun 19,201510:55:11AM EDT DIN: 20141029-IR-326140441FDA Page 4Indiana Register (2) On or before May 1, 1996, all workers, including contractors, shall have completed a training program if they engage in any ofthe activities listed in subdivision (3). (3) The training program may include training provided by the manufacturer or supplier of coatings, cleaning materials, or the application equipment thereof, and shall include written procedures, hands-on demonstration, as appropriate, and certification by the trainer ofthe trainee's ability to perform the task, on the following activities:

(A) Identification of appropriate coatings or cleaning materials. (B) Preparation of coatings or cleaning materials according to coating or cleaning material manufacturer, distributor, or owner or operator's recommendations. (C) Application of coatings or cleaning materials, or organic solvents using techniques that minimize their usage. (D) Procedures to clean spray guns to minimize evaporation of organic solvents to the atmosphere. (E) Work practice standards established in subsection (b). (F) Procedures to gather, record, monitor, and report data in accordance with section 7 ofthis rule. (4) Beginning in 1997, the owner or operator shall provide annual refresher training prior to May 1 to any worker performing one (1) or more ofthe activities listed in subdivision (3). Such training shall be appropriate to the job responsibilities ofthe worker. (5) Any worker may perform one (1) or more activities listed in subdivision (3), for not more than one hundred eighty (180) days, notwithstanding the requirement of subdivision (2), provided:

(A) such untrained worker works under the supervision of a worker who meets the training requirements of subdivision (2); and (B) the owner or operator keeps records of:

(i) the date the worker was assigned to the activity; (ii) the date training was completed; and (iii) the name ofthe worker providing the supervision. (6) The owner or operator shall keep records ofthe training program. The records shall consist ofthe following: (A) The date training was completed. (B) A list of workers by name and worker activities listed in subdivision (3) in which each worker has been trained. (C) A .statement signed by the person providing the training certifying that the worker completed training and is proficient in the activities listed in subdivision (3) in which the worker will be engaged. (Air Pollution Control Division; 326 ·lAC 8-12-4: filedApr 1, 1996, 10:00 a:m.: 191R 1753; filed Jw?· 15, 2001, 12:08 p.m.: 241R 3613)

Notice of Public Hearing

Posted: 10129/2014 by Legislative Services Agency An html version ofthis document.

Date: Jun 19,201510:55:11AM EDT DIN: 20141029-IR-326140441FDA Page 5( ( INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers and OurEnvironment.

Michael R. Pence Govemor 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



### December 2, 2014



### CERTIFICATE OFPUBLICATION Thomas W. Easterly Commissioner



### This is to certifythatthe Indiana Department ofEnvironmental Management (IDEM) Notice of Publi.c Hearings'for the Environmental Rules BoardMeeting, 01/14/2015, regarding the following rulemaking actions:

• PreliminaryAdoption, Walsh & 

### Kelly S02

### Limits, LSA# 14-256 • PreliminaryAdoption, Shipbuilding & 

### Ship Repair,**~SA** 

### #14-441 • Prelimimiry Adoption, Particulate Matter EmissionLimits, LSA #12-520 • PreliminaryAdoption, S02 

### EmissionLimits, LSA#11-356

waspublished onIDEM's web site onorbefore December 8, 2014. It

### will remainposted onthe site until at least January 14, 2015.

{ r · 

### Thenotice infull maybe found atthe following web address, underthe "Statewide" category.

{I 

### http:/ /www.in.gov/idem/6777.htm Web publication ofthe notice was attherequest ofChristine Pedersen, Sectjon Chief, Rule Development Section, Office ofLygal Counsel, IDEM.

Attachments: Copy ofweb page as published. By:

Mike Finkelstein IDEMWebmaster

AnEqual OpportunityEmployer 

# 0

AStatethatWorks 

# - G) RecycledPaper1ifIDEMHomeAboate·SeiVIcesFeaturedTopicsNewsandEventsPublleNoticesFactSheetsFormsMapsRulesContaaInformationAholltYourEnvironmentAlrQoalltyA1rToxics:ProgramBlue-Grcen.AJ'gaeCommunilyEnvironmemalHealthC'fAP:ComplianceandTechnicalAssistanceProgramEnvkonmenra(CieanUJlEnvltorunt!ntalEducationEnvtronmemafJustJceHooslerRivenvatchP.attnersforPollutionPre.vemlooPot!tulanPrevent!onRecycreIndianaWasteTlreP.rogramWaterQUaUcyPublicNotices:StatewideThisistheIDEMPubfieNoticaSitenotioascoveringtheentireStateoflndianaThispageisdesfgnedtoprovidepublicaccesstoallagencystate-widepublicnoticesasrequiredbystatuteorruleincluding:PCIIIlitting,rulemaking,meetingandbearingnotices.·Cfickhighlightedlinkstoviewadr!itionalinformationraate<ftothenotice.Forpublicmeetingsnotr<lQuiringpleasechecktheIDEMCalendar.Subscriptions:Wanttoknowaboutnewnoticesassoonasthey'reposted'lYoucannovtsubscribetothisregionalpublicnoticepage.Bysubsctib.ingtoafegion,youwillbesentane-mailortextmessagetoyourphoneeverytimeIDEMaddsinformationtothisregionalpage.Thisallowsyoutostaycurrentonallpastingandnevermissanewposting.Tosubscribe,clickonthesubscriptionliiikinthelefthandcolumn.•·DrnfrSectlon401Belssmmg:forRGpTuc:oday,Decetnbr::rCt2,20_1Q.Occember.2014i !

i ; 

### LegalNotice ofPublic Hearing·

t • 

### Under40 CFR51.102, notice is hereby giventhatthe EnvironmentalRules Board (board) will hold a public hearing atits regtllarly scheduledmeeting onWednesday, January 14, 2015, for the airprogram rules listedinthis notice. The meetingwill. convene**a~** 

### 1:30 p.m. atthe Indiana GovernmentCenter-South, ConferenceRoomA, 302 WestWashington Street, Indianapolis, Indiana. The purpose ofthehearings is to receivepublic comments priortoboard actions. All interestedpersons are invited andwill be given a reasonable opportunity to· expresstheir views concerningtheproposed actions. Board documents maybeviewed and downloaded from the IndianaDepartment of Environinental Management's Web site as**~arly** 

### as one weekprior to the me·eting at http://www.in.gov/idem/4696.htm

.

• t 

### Copies oftheproposed air·programrules are also available to anypersonupon**r~quest,** 

### maybe viewed 6nline 'via•the· Internetfi:om

### ~ocallibra:des, a,nd are available for public inspeetion atthe following locations: Indiana**Departm~nt** 

### ofEnvironmtnital Management, Offiee of:Legal Counsel, Indiana Government Center..,North, 

## l QO.North Senate .Avenue, 13thFloor,**Indian~polis,** 

### Indiana46204. Indiana :Oepartment ofEnvironmental Management,NorthwestOffice, 3 30 .WestUS Highway30, Suites E and F,Valparaiso, IN 46385. · ' fudi:ana Departmentof:Environmental'Management, Northern Of:fice, Scite450, 300N. ., Michigan Street, So1,1.th Bend,'Indiana46601.

. . ', IndianaDepartment ofEnvironmental Management, Southwest Office, 1120 North Vincennes Avenue, P.O. Box 128, Petersburg, Indiana47567-0128. " IndianaDepartment ofEnvironmentalManagement, Southeast Office, 840 West Sweet · Street, BrownstoWn; Indiana

### A 7220;'9557. Legislative Services Agency, IndianaGovernment Center-North, 100 North**~enate** 

### Avenue, RoomN201, Indianapolis, Indiana46204. Thefollowitt@'>ailYprogi:amrules ate.noticed for hearing and action: Walsh and Kelly SOzLimits. LSA#14;.156. The purpose ofthis hearing is to receive public commentprior·to prel:iJ:ninary adoption of amendments.to 326 IAC 7,..41:1-21 concerning sulfur dioxide emission·limits to addanew · aggregate dzyer/bmner· at

### yYalsh and Kellyin Griffith, Indiana. Thisrule will be· submittedto the United States·Envitonmental ProtectionAgency as a revisionto the State ImplementationPlan requiredbythe CleanAir Act. A copy ofthe mostrecentlypublishedversion ofthis rule is available at: http://www.in.gov/idem/5679.htm. For additional information concerning this rule contact.SusanBern atthe Indiana Department ofEnvironmentalManagement, Office ofLegal Counsel, Indiana Government CenterNotth; 100:North SenateAvenue, Indianapolis at (317) 233-5697 or (800) 451.,6027 (ext. 3-5697) (in Indiana), or sbem@idem.in.gov. ' Shipbuilding and Ship Repair. LSA#14-441..

### Thepurpose ofthis hearingis to receivepublic commentpriorto preliminarY'adoption of amendments to 326 lAC 8-12-4 concerningtherevision ofa yolatile organic compound content limitfor antifoulant coatings to be consistent withthe federal NationalEmission Standardfor Hazardous AirPollutants for Shipbuilding and Ship Repair. This rule willbe submittedto theUnited States EnvironmentalProtection Agency as a revisionto the State ImplementationPlanrequiredbythe CleanAir Act. A copy ofthe mostrecentlypublished version ofthis ru1e is available at: http://www.in.gov/idem/5679.htm. For additional information concerning-this rule contact SusanBern at the Indiana Department ofEnvironmentalManagement, Office ofLegal Counsel, Indiana Government CenterNorth, 100North SenateAvenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 3-5697) (inIndiana), or sbem@idem.in.gov: Particulate Matter Emission Limits. LSA#12-520.

. The purpose ofthis hearing is to receive public commentpriorto preliminary adoption of amendments to 326 IAC 6.5 and 326 lAC 6.8 concerningparticulatematter emissionlimits. This rulemaJdp.g proposes to update·information,·make corrections; and addres$ changes requestedby sources, includingmodifications to Jupiter Alu_minum andHuhtamaki Foodservice·. This rule wilLbe submittedto the United States Environmental ProtectionAgency as.arevision· to the State ImplementationPlanrequired bythe CleanAirAct. 

### A: copy, o:Bthe mos1lrecently publishedversion oft4isrule:is available at: http://www'.in,gov/idem/5679.htm. For additional information concerningthis.ru1e**cont~ct** 

### SusanBemat the Indiana. Department ofEnvironmentalManagement, Office of.Legal Counsel; Indiana.Government CenterNorth, 100 Nortlr SenateAvenue, Indianapolis at (317) 233-569? or. (800) 451;.6027 (ext. 3-5697) (in Indiana), orsbem@idem.in.gov. ·



### ·SOz Emission Limits. LSA#11-356. Thepurpose ofthis heatingis to receivepublic commentpriorto preliminary adoption of amendments to 326 IAC 7 concerningthe addition ofsulfur dioxide emissionlimits, effective January 1, 2017, to address State Implementation Planrequirements for Marion, Morgan, Pike, andVigo counties thathavetownships designated as nonattainment for the 1-hour standard. This rulemaking also proposes updating and conectinginformation, and removingunits or sources that are no longer operating. This rule will be submittedto the United States Environmental ProtectionAgency as a revisionto the State ImplementationPlanrequired bythe CleanAir Act. A copy ofthemostrecentlypublishedversion ofthis rule is available at:· http://www.in.gov/idem/5679.htm.

. For additionalinformation concerningthis rule contact SusanBern atthe Indiana· Department ofEnvironmentalManagement, Office ofLegal Counsel, Indiana Government Center**North~** 

### 100North SenateAvenue, Indianapolis a! (317) 233-5697 or (800) 451-6027 (ext. 3-5697) (in Indiana), or sbem@idem.in.gov. ·

Forthese hearings, oral statements will beheard, but for the accuracy ofthe record, please submit statements inwritingto the attendant designated to receive written'comments at· thepublic hearing. · A transcript ofthehearings and all written submissions to the board atthe public hearing shall be opento public inspection atthe.IndianaDepartment ofEnvironmental Management; ! :I ! 

### copies may be made available to anypersonuponpayment ofreproduction costs. Anyperson heard or represented atthe hearings orrequesting notice shallbe given written notice ofthe actions ofthe board. Christine Pedersen, Chief Ru1es Development Section Office ofLegal Counsel 

## ****************************************************************************** Individuals requiring reasonable accommodations for participationinthis event should contact ·the IndianaDepartment ofEnvironmental Management, Americans withDisabilities Act coordinator at: Attn: ADA Coordinator IndianaDepartment ofEnvironmental Management 100N. SenateAvenue Indianapolis, IN 46204

or call (317) 233-1785. Speech andhearing impaired callers may contactthe agency viathe Indiana**~elay** 

### Service at 1-800-743-3333. Pleaseprovide a minimum of

## 7'2 hours' notification.INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers andOurEnvironment. 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov Michael R. Pence Governor Thomas W. Easterly Commissioner 

### February 3, 2015

. 

### CERTIFICATE OF PUBLICATION This is to certifythatthe IndianaDepartment ofEnvironmental Management (IDEM) Notice of Public Hearings.for theEnvironmental Rules BoardMeeting, 03/11/2015, regardingthe following**rulem~ng** 

### actions:

• FinalAdoption, Walsh & 

### Kelly S02

### LiJ?its, LSA #14-256 • FinalAdoption, Shipbuilding & 

### Ship Repair, LSA#14-441 • FinalAdoption, Particulate MatterEmission Limits, LSA #12-520 • Preliminary Adoption, S02EmissionLimits, LSA#11-356

was published onIDEM's web site onor before February 6, 2015. 

### Itwill remainposted onthe site until atleastMarch 11, 2015.

1'. 

### The notice infull maybe found atthe following web address, underthe "Statewide" category. http://www.in.gov/idem/6777.htm Web publicationofthenotice was. at the request ofChristine Pedersen, Section Chief, Rule Development Section, Office ofLegal Counsel, IDEM

..

Attachments: Copy ofweb page as published.

AnEqual OpportunityEmployer 

### By:

Mike Finkelstein IDEMWebmaster 

# 0

AStatethatWorks 

# - G) RecycledPapertDEMHcmeAhoote-SeFVlcesPubli·cNon·ces:StatewideFeatmed1opitsNewsandBrentsThisistheIDEMPublicNotilleferrrotieescu.verln!JitheentireState·oflndianaThispageis<l:esignedtoprovidePubllcNoticespublicaccesstoallagencystate-widepublicno1Iicasasre![uiredbystatuteorruleincluding:permitting,fcrshee•rulemaking,meetingandhearingrrotices.Clickhighlightedlinkstoviewadd"ilionalinliarmation'II!!Iatedtothenotice.arsForpublicmeetingsootrequirin!Jinotices,.please·checktheIDEMCalendar.FollilSMapsRuJescootactl!Uifol!'maU!iiXIAbomYomEnvironmentAii'QllalllyAilrTOxtl:SProg,rnmBlne"GreenAigaeCommlll1llyEnvlromnentalHealth·CfAP:ComJ)UanceandTechnicalAssistanceP!ogmmEnvironmentalCleanupBmlironmemanEducanimEnvironmentaiJI!SticeHoosierRlverwatcllPannersforPollutJonPrevent!anPoUmionPreventfonRecycleIndianaWasteTilePro!J!1llllWate.tluaTityWate.slledsamiwate.PolllnloJ!WMI.:uu!r;:I>Sullscriptions:W<mtt-oknewaboutnewnoticesassoonast!ley'repGSted?Youcannowsubscribetathisregionalnctiee[)age.Bytoaregion,youwillbesentane-mailortextmessagetoyeurphoneeverytimeIDEMaddsinformationtothisr·egi0nalpage.11lisallowsynuto:stayeurrentonallpostingandnevermissanewposting.To:subscribe,dickonfhe:subscriptionlinkinthe[efthandcolumn.liuesday,2!115februaty,2lll5Stl!Mcr'JuWelihF1S•1.z!3il4551S9l0Dl21314l5l&171819202l2223252527281234557.:-...·:;:..._.(I

I. I

I. 

### Legal Notice ofPublic Hearing·



# . Under 40 CFR 51.102, notice is hereby given that the EnvironmentalRules Boal'd (board}will hold apublic·hearing atits**regul~ly** 

### scheduledmeeting onWednesday, March·ll, 2015, for the air:program rules listed in

### this notice. The meeting will convene at 1:30-p.m. atthe fudiana ,.**Gove~ent** 

### Center-South, Conference Room A, 302 West Washington Street, Indianapolis, fudiana. The purpose ofthehearing$ is to receive pq.blic c;omments,priorto board actions. All interested·persons are invited and will be given areasonable opportunity to express their views concetning theproposed actions; Board documents may be viewed and downloaded from the. IndianJl:Department of

. Environmental Management's Web site as early as one weekpriorto the meeting at http://www.in.gov/idem/4696.htm. · It 

### Copies ofthe proposed**air·program~es** 

### are also available to any personupon.request,.maybe. viewed nnline-via·tb.e·futemet-from locttllibraries, arid are available fot public inspectionattq,e folloWing locatiorts:o

. : ,. ·, . . : I • • , ·,, 

### :·hi

### diana: :Depattm.ep.t ofEnvironn'lental Management, Office ofi

### Legal.Gol.iusel,· fudian<=!; ·

, Government**Cent~{,:tfodh;•**

## lDONo:rth Sen,ate Avenue, 13thFloor-;<fudianapolisst**fudian~**

### 46:204; : fudianaJDepartmeht ofEnvironmentalManagement; Northwest Office, 330 ·westUS·.·**Highway30~ Suit~s.EandF,.Valparaiso~**  

### IN 4638§; · ·**~-** 

### ...; · .· •:**.~** 

### . l· · •·



### . · · Ihdiru;taDeparttn'entofErivir6ninental Management, Northem Office, SUite 450, 300N. Michj.gari Street, SouthBend, Indiana46601. ·**~~-** 

### ... 1. !,:' · :: ,. 

### Indian.aDepartment ofEnvironmental Management, Southwest Office, 1120 North Vincennes Avenue, P.'O. Box 128, Petersburg, Indiana 47567-0128(

.. ·· .. · . · ·. ·-I:rldianaiDep'artmento:fEnvironmental Management, Southeast Office, 820 West Sweet Stre-et, B±ownsto'Wn,tlndiana:47220-9557, : · ' Legislative·Seivice8.Agency, Indiana**Gove~ent** 

### Center.:.Nmih, 100 No'lih Senate Avenue,.Room·N20l,.Ihdiana:polis; Indiana46:204. , , ·. 

## . . '· ',· 

### The following af.fptogram rules are noticed for hearing and action: Walsh and Kelly 

### SOz Limits. 

### LSA #14-256. The purpose ofthis hearing is to receive public _commentpriorto 

## fip.a.I a.¢tgptio:p. of · amendments-to 326 lAC 7'-4!1-21 conceming sulfur dioxide emission limits to add anew ·aggregate dryer/burner1

### at Walsh and Kelly in Giiffith, fudiana: This rule will be submittedto the Urtited**Stat~s'**

### EnvironmentalProtection.Agency as areyisionto the State hbplementation Planrequired by the Clea,nAir Act. A copy ofthemost recently-published version o£this**:rul~** 

### is available at: http://www.in.gov/idem/5679.htin. For additional information concerning this rule contact SusanBern atthe Indiana Depmimentof'Environmental.Management, Office ofLegal Counsel, Indiana Government CenterNo1ih, 100 North Senate Avenue, Indianapolis at (317) 233-5697or (800) 451-6027 (ext. 3-5697) (in Indiana),**~r** 

### sbem@idem.in.gov. Shipbuilding arid Ship Repair. 

### LSA #14-441.

### The purpose ofthis hearing is .to receive public commentprior to final adoption of · amendments to 326 lAC 8-12-4 concerning the revision ofavolatile organic compound content limit for antifoulant coatings to be consistent withthe federal National'Emission Standard for Hazardous Air Pollutants for Shipbuilding and Ship Repair. This rule willbe submittedto the United States Environmental ProtectionAgency as arevision to the State. Implementation Planrequired by the Clean Air Act. A copy ofthe mdstrecently published version ofthis rule is available at: http://www.in.gov/idem/5679.htm. For additional information concerningthis rule contact SusanBem atthe Indiana Department ofEnvironmental Management, Office ofLegal Counsel, Indian!:\- Goverru.:nent CenterNorth, 100 North SenateAvenue, Indianapolis at (317) 233-5697 or (800) 451-602T(ext. 3-5697) (in Indiana), or sbem@idem.in.gov.

.l! ,, ' 

### ParticulateMatterEmissionLimits. 

### LSA #12-520. The purpose ofthis hearing is to receive public commentpriorto fmal adoption of amendments to 326 lAC 6.5 and 326 lAC 6.8 concerning pmiiculatematter emissionlimits. This ruleniaking proposes to update information, make correcti.ons, a:p.d**addres~:** 

### Qhanges · · , requestedby**spurces~** 

### inchidin'gmodifications to Jupiter:Aluminum and HuhtamakiFo.odservi¢e. This rule will be submitted to the United States Environmental ProtectionAgency as a**r~:visiou,** 

### to the**State.Implem'eht~tioii· ~Ian,** 

### tetpiired J:?y the' CleanAir Act\ A cop"y1 ofthe: most-recently**published~vefsion** 

### oftllls riileiis 1

### available at: http\//www.in.gov/idem/56T9.htm

... · · ... '

.,· Fm'-'cidditional information concerningthis rule contactSusan Bem**at·the-Indian~** 

### Department ofEnvironmental Management, Office ofLegal Counsel; Indiana**Govennn~nt** 

### CehtetNonh, 100'N 01i:(Y Senate :A 

### venue, Indianapolis at (317}233:-5697. or (800) .451'-6027 (ext. 3-5697) (in Indiana), or sbem@idem.ill.gov. · .j • !' 

### SOz EmissionLimits. 

### LSA;#11-356. · The :(:h:itpose 

### ofthis heai;ingis to receive.public commentpriorto pnd@inary adoption of amendments to 326 lAC 7 concerning the addition ofsulfur dioxide emission limits, effectiVt;} · January 1, 

### 2017**~** 

### to address State Implementation Planrequirements for·Marion, Morgap., Pike, and Vigo counties,thathave townships designated· as nonattainmentfot the 1 :..hour**stand~d.;**

### This rulemaking also proposes updating and conecting information, and removing units oi: sources that are no longer operating. ·This nile 

### will be submittedtothe United States.Envirpnmental· : Protection Agency as a revisionto the State ImplementationPlanrequired by tlie CleanAir Act. 

# Acopy ofthe mostrecentlypublished version ofthis rule is available at: · · · · : ,· http:/ /WwW'.in.g'ov/idetn/661.9,htm,. For**add~tional·**

### illformatio:ri concerning this rlll.e contact Susan Bern atthe Indiana Depmiment ofEnVironmental Management, Office ofLegal Counsel, Indiana Government. CenterNorth,**~100** 

### North SenateAvenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 3-5697) (in Indiana), or sbem@idem:in.gov.

Forthesehearings, oral statements will be heard, but for the accuracy oftherecord, please submit statements in writing

## to the attendant designatedto receive written comments at thepublic hearing. Atranscript ofthehearings and.all written submissions to the board at the public hem·ing shall be open to public inspection at the IndianaDepmiment ofEnvironmental Ma1;1agetnent; ( I\I 

### copies maybe made available to any personupon payment ofreproduction costs. Anyperson heard or represented at thehearings or requestingnotice shallbe given writtennotice ofthe

. actions ofthe board. Christine Pedersen, Chief Rules Development Section Office ofLegal Counsel**********************~*********************************************************** 

### Individuals requiring reasonable accommodations for pmiicipationinthis event should contact the IndianaDepartment ofEnvironmental Management, Americans withDisabilities Act coordinator at: Attn: ADA Coordinator IndianaDepartment ofEnvrronmentalManagement 100N. SenateAvenue Indianapolis, IN46204

or call (317) 233-1785. Speech andhearing**imp~;~.ired** 

### callers may contactthe agency viathe Indiana Relay Service at 1-800-743-3333. Pleaseprovide a minimum of72 hours' notification.t ( 1 2 3 4 5 6 7

I 8 9 10 11 I t 12**~** 13 14 15 16 17 18 1!j 20 21 22 23 I I ,;;' 

### BEFORE THE STATE OF INDIANA ENVIRONMENTAL RULES BOARD

PUBLIC MEETING OF JANUARY 14 1 2015 

# ORtGtNAL

PR09EEDINGS before the Indiana Environmental Rules Boardr 1



### Beverly Gardr Chairman 1 

### taken before mer 

### Lindy L. Meyer 1 

### Jr. 1 

### a Notary Public in and for the State of Indiana 1 

### County of Shelby 1 

### at the Indiana Government Center South 1 

### Conference Center 1 

### Room Ar 402 

### West Washington Street 1 

### Indianapolis/ Indiana 1 

### on Wednesday/ January 14, 2015 

### at 1:29 

### o'clock p.m.

William F. Daniels, RPR/CP CM d/b/a ACCURATE REPORTING OF INDIANA ) 12922 

### Brighton Avenue

Carmel, Indiana 46032 (317) 848-00881 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

:.... 

### APPEARANCES: BOARD MEMBERS: Beverly Gard 1 

### Chairman Thomas R. Anderson Gary Powdrill Joanne Alexandrovich Kelly Carmichael Ken Rulon William Etzler Chris Horn Gail Boydston Calvin Davidson Mike Mettler 1 

### Proxy 1 

### Department of Health Cameron Clark 1 

### Director 1 

### Department of Natural Resources Pamela Fisher 1 

### Proxy 1 

### Indiana 'Economic Development Corporation David Bausman 1 

### Proxy 1 

### Lieutenant Governor Thomas W. Eas.terly (nonvoting) IDEM STAFF MEMBERS: Christine Pedersen Susan Bern Dan Watts Bruce·Palin Nancy King Janet Pittman Roger Letterman PUBLIC SPEAKERS: Josh Trenary Andrew Gilbert Bill Beranek Bowden Quinn Vince Griffin Andrew Berger Glenn Pratt Ralph Roper (via Dr. Beranek) David Wagner (via Dr. Beranek) Larry Kane 2

l '

! I(! 

### 1 2 3 4 5 6 7 8 9 10 11 (; 

### 12 13 14 15 16 17 18 19 20 21 22 23 CHAIRMAN GARD: 1:29 o'clock p.m. January 14, 2015

Thank you. I will call the January 14th, 2015 meeting of the Indiana Environmental Rules Board to order. There is a quorum present. Let's go around the

room as usual and introduce ourselves and what constituency you were appointed to represent. Kelly? MR. CARMICHAEL: Sure. Kelly Carmichael, utilities. MR. HORN: Chris Horn, labor. 3



### MR. DAVIDSON: ,Calvin Davidson, solid waste. DR. ALEXANDROVICH: Joanne Alexandrovich, local government. MR. RULON: Ken Rulon, agriculture. MR. POWDRILL: Gary Powdrill, the general public. MR. ANDERSON: Tom Anderson, environmental. MR. ETZLER: Bill Etzler, small business.4 

### I r 

### 1 CHAIRMAN GARD: Beverly Gard, general 2 public. 3 MS. BOYDSTON: Gail Boydston, 4 manufacturing. 5 MS. FISHER: Pam Fisher, proxy, 6 Secretary of Commerce Victor Smith. 7 MR. METTLER: Mike Mettler, proxy for 8 the State Health Commissioner, Dr. Adams. 9 MR. CLARK·: Cam Clark, Director for 10 the Indiana Department of Natural Resources. 11 MR. BAUSMAN: David Bausman, proxy 12 for the Lieutenant Governor. 13 COMM. EASTERLY: Tom Easterly, the 14 Commissioner of IDEM, nonvoting. 15 CHAIRMAN GARD: Thank you. 16 The first order of business today is the 17 approval of the summary of the November 12th, 18 2014 Board meeting·. Are there any additions or 19 corrections to the summary as distribtited? 20 (No response.) 21 CHAIRMAN GARD: Seeing**n~ne,** 

### is there 22 a motion to approve the minutes as distributed? 23 MR. POWDRILL: So moved.



### -

-- i I( i 

### 1 2 3 4 5 6 7 8 9 10 11 ( i 

### 12 13 14 15 16 17 18 19 20 21 22 23

- ( l 

### MR. CLARK: Aye

. MR. METTLER: Aye. MR. DAVIDSON: Aye. MR. RULON: Aye. DR. ALEXANDROVICH: Aye. MR. CARMICHAEL: Aye. CHAIRMAN GARD: Aye. Opposed 1 

### nay. (No response.) CHAIRMAN GARD: preliminarily adopted. The rule is

This is a 'public hearing before the 37



### Environmental Rules Board concerning preliminary adoption of amendments·to rules**~t** 

### 326 IAC 8-12-4 regarding Shipbuilding and Ship Repair. I will now introduce Exhibit C 1 

### the draft rules 1 

### into the record of the hearing. Susan Bern. MS. BEM: Again 1 

### name is a .Susan Bem 1 

### and I work in the Rules Development Branch. IDEM regulates volatile organic compound 1 

### or VOC 1 

### emissions from surface coating operations. at shipbuilding and ship repair facilities in1 

### Article 8-12. The rule

-- this rule was 2 originally adopted in 1995 to address ozone 3· nonattainment areas classified as moderate or 4 above and is limited to facilities in Clark, 5 Floyd, Lake and Porter Counties. 6 

### This rulemaking was requested by the one 7 affected source 1 

### Jeffboat 1 

### a barge manufacturer 8 located in Clark County, to address the limited 9 availability of antifoulant coatings. Section 38

10 4 

### (a) ( 1) (E) of the rule indicates that specialty 11 coatings .not specifically listed shall not exceed 12 a VOC content of 2.83 pounds per gallon. 13 Antifoulant coabings are not specifically 14 listed and are not**~-** 

### and are subject to the 15 2.83-pounds-per-gallon limit. The· an.tifoulant 16 coating that Jeffboat was using with a VOC 17 content that meets the 2.83-pounds-per-gallon 18 limit was.discontinued by the supplier and is no 19 longer available. 20 IDEM had adopted this limit in the 1995 21 rule to meet Clean Air Act deadlines before the 22 U.S. EPA had finalized the Control Technique 23 Guidelines for this source category and before ( i

I '( (

1 2 3 4 5 6 7 8 9 10 11 i' 12 13 14 15 16 17 18 19 20 21 22 23 

### the EPA finalized the National Emission Standard for Hazardous Air Pollutants, or NESHAP, for 39



### shipbuilding. The CTG's are developed by EPA to · assist states in analyzing and determining reasonable available control tebhnology, or RACT, for sources located in ozone nonattainment areas. With this rulemaking, IDEM is proposing an antifoulant VOC content limit at 3.3 

### pounds per gallon, and this is**con~istent** 

### with the limit that ended up in the final NESHAP and the final CTG that was issued by EPA after the original rule was adopted in 1996. 

### There are two antifoulant coatings remaining on the market that meet the more stringent Indiana requirements in Article 8, but neither of these are appr6priate for Jeffboat. One is designed for yachts, not barges, and the other is cost prohibitive. A customer may request a specific manufacturer and coating system to be used on a barge. If Indiana sources cannot offer the same options as other manufacturers in other states, they may have to decline business or**~end** 

### the1 2 3 4 5 6 7 8 9 10 11 12 13 14; 15 16 17 18 19 20 21 22 23

:,_ 

### barge to an outside independent shipyard in another state for surface coating. Suppliers do not go to the expense to test antifoulants with other suppliers' epoxy resins, and do not warranty their coating systems with**oth~r** 

### suppliers' antifoulants. 40



### The current limit in Article 8 is part of the Indiana State Implementation Plan, or SIP, and once this rulemaking is final, we'll submit it to EPA for SIP approval. The Department**requ~sts** 

### that the Board preliminarily adopt the rule as presented. Any questions?· CHAIRMAN GARD: Any questions for Susan? DR. ALEXANDROVlCH: Can I just comment. CHAIRMAN GARD: Yes. DR. ALEXANDROVICH: on -- CHAIRMAN GARD: Certainly. DR. ALEXANDROVICH:

-- something? In the proposed changes to the rule, some dates are kind of crossed out,_ and then there are some that ( r

### 41

1 

### are left, II 

### .. before January 1[st]

... 96." Is 2 this the appropriate time to mention it? 3 

### CHAIRMAN GARD: Do you want to 4 address that, please? 5 

### MS. BEM: Yes. 6 

### DR. ALEXANDROVICH:. On page 3 and 4. 7 

### MS. BEM: Yeah. The initial date in 8 the rule was crossed out so that it didn't look 9 

### like 1 

### now that we were changing the antifoulant 10 coating limit from 2.83 to 3.3, that the 3.3 11 

### limit always applied. So, it would.make ·the 12 so it's

-- in that initial section, Section 4i we 13 crossed out the date, and, ·you know, that

-- once \ 

### 14 these changes are effective, those are the limits 15 that will apply from that date forward. 16 

### DR. ALEXANDROVICH: Right. There are ·17 still some dates that 18 MS. BEM: Yeah. 19 

### DR. ALEXANDROVICH: have not been 20 crossed out, so I was wondering if that was just 21 an oversight or if there was a reason for that. 22 MS. BEM: And then some of the other 23 dates, as we went through

-- but we felt like we

### 1 2 3 4 5 

### 6 7 8 9 10 11 12 13 14 15 

### 16 17 18 19 20 21 22 23 should leave those dates in there because they

were training program dates, and we wanted to make sure people knew there was a difference for

-- when certain parts of the rule, you know,

were applicable. DR. ALEXANDROVICH: Okay. 42



### MS. BEM: So, we thought there was -- DR. ALEXANDROVICH: I gotcha. MS. BEM:

-- a reason to keep those in this. (Discussion off the record.)

/ 

### MR. ETZLER: I honestly think in the realm of consistency,**si~ce** 

### the 1996 date has passed, that ·the rule should state that you have to be in compliance, so I don't think elimination of ·the date creates a problem, because today you would have to have a**~raining** 

### program. So, I

concur with the Doctor that

-- I think those dates should be eliminated. MS. BEM: Okay. MR. ETZLER: I certainly would like you to look at that before we finally adopt the rule.43



### MS. BEM: Before final adoption,

we 1 

### ll definitely go back**~nd** 

### take a look at that and give that some consideration. MR. ETZLER: Thank you. CHAIRMAN GARD: Yes, Cal. MR. DAVIDSON: If there becomes a -- if the second available antifoulant becomes unavailable, then they have to go to the more expensive product at some time in the future and shipbuilding just becomes more expensive, I

- 

### guess. Would**~e** 

### -- would it require another**~evision,** 

### or have you looked at that other alternative? Would we have to do this again if they go to another product? MS. BEM: We --hopefully we wouldn 1 

### t have to do this again, since the limit that we 1 

### re putting in the rule, the 3.3 pounds per gallon, is the same limit that 1 

### s applicable in every other state because of the National Emission Standards for Hazardous- Air Pollutants, that there 1 

### s enough manufacturers out there. You know, since they 1 

### re not just having a supplier from one state, they 1 

### re supplying for all barge

### 1 2 3 4 5 6 7 8 9 10

. 11

12 13 14 15 16 17 18 19 20 21 22 23

=:... 

### manufacturers[ that hopefully

-- you know[ it would cause a problem for all barge manufacturers[ not just the Indiana ones 1 

### so hopefully we ·wouldn't have ·to go back. It wouldn't be a problem in the future. MR. DAVIDSON: Thank you. CHAIRMAN GARD: Any other questions? (No response.) CHAIRMAN GARD: Thank you 1 

### Susan. MS. BEM: Thank yqu. 

### CHAIRMAN GARD: We don't have any speaker cards. Is there anyone in the audience that would like to comment on this rulemaking? (No ri='sponse.) CHAIRMAN GARD: Seeing none 1 

### the hearing is concluded. The Board will now consider preliminary adoption of amendments to the Shipbuilding Rules at 326 IAC 8-12-4. Any Board discussion

-- any more Board discussion? (No response.) CHAIRMAN GARD: Is there a motion to

-- for preliminary adoption of the rule? MR. ANDERSON: So moved. 44

### 45 II 1 

### CHAIRMAN GARD: Is there a second? 2 

### MR. DAVIDSON: Second. 3 

### CHAIRMAN GARD: All in favor 1 

### say 4 

### aye. 5 

### MR. HORN: Aye. 6 

### MS. FISHER: Aye. 7 

### MS. BOYDSTON: Aye. 8 

### MR. ETZLER:. Aye. 9 

### MR. ANDERSON: Aye. 10 

### MR. BAUSMAN: Aye. 11 

### MR. POWDRILL: Aye. 12 

### MR. CLARK: Aye. 13 

### MR. METTLER: Aye. 14 

### MR. DAVIDSON: Aye. 15 

### MR. RULON: Aye. 16 

### DR. ALEXANDROVICH: Aye. 17 

### MR. CARMICHAEL: Aye. 18 

### CHAIRMAN GARD: Aye. 19 

### Opposedr nay. 20 

### (No response.) 21 

### CHAIRMAN GARD: The rule is 22 

### preliminarily adopted. 23 

### This is a ·public hearing before the

=- j. I l 

### 1 2 3 4 5 6 7 

### 8 9 10 11 [' 

### 12 13 14 15 16 17 18 19 20 21 22 23 

### CHAIRMAN GARD: With a motion and a second, we are adjourned. Thereupon, the proceedings of January 14, 2015 were concluded at 3:·35 o'clock p.m. 121122

1 

### CERTIFICATE 2 

### I, Lindy L. Meyer, Jr., the undersigned 3 

### Court Reporter and Notary Public residing in the 4 

### City of Shelbyville, Shelby County, Indiana, do 5 

### hereby certify that the foregoing is a true and 6 

### correct transcript of the proceedings taken by me 7 

### on Wednesday, January 14, 2015 

### in this matter and 8 

### transcribed by me. 9 10 11

# ~ot~~~ V· # Lindy L. Meyer,**Jr.~** 12 

### Notary Public in and 13 

### for the State of Indian0. 14 15 

### My Commission expires October 27, 2016, 16 17 18 19 20 21 22 23Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION Proposed Rule LSA Document #14-441 DIGEST Amends 326 lAC 8-12-4 concerning antifoulant coatings used at shipbuilding and ship repair facilities. Effective 30 days after filing with the Publisher. HISTORY Findings and Determination ofthe Commissioner Pursuant to IC 13-14-9-7 and Second Notice of Comment Period: October 29, 2014, Indiana Register (DIN: 20141 029-IR-326140441 FDA). Notice of First Hearing: October 29, 2014, Indiana Register (DIN: 20141 029-IR-326140441 PHA). Date of First Hearing: January 14, 2015. SUMMARY/RESPONSE TO COMMENTS FROM THE SECOND COMMENT PERIOD IDEM requested public comment from October 29, 2014, through December 1, 2014, on IDEM's draft rule language. No comments were received during the second comment period. SUMMARY/RESPONSE TO COMMENTS RECEIVED AT THE FIRST PUBLIC HEARING On January 14, 2015, the Environmental Rules Board (board) conducted the first public hearing/board meeting concerning the development of amendments to 326 lAC 8-12-4. No comments were made at the first hearing. 326 lAC 8-12-4 SECTION 1. 326 lAC 8-12-4 IS AMENDED TO READ AS FOLLOWS: 326 lAC 8-12-4 Volatile organic compound emissions limiting requirements Authority: IC 13-14-8; IC 13-17-3-4 Affected: IC 13-12 Sec. 4. (a) On and after May 1, 1996, The owner or operator of a shipbuilding or ship repair facility subject to this rule shall comply with the following VOC emissions limiting requirements: (1) Provisions applicable to specialty coatings are as follows:

(A) Special marking coatings shall not exceed a VOC content offour and eight-hundredths (4.08) pounds per gallon. (B) Heat resistant and high-gloss coatings shall not exceed a VOC content ofthree and fifty-hundredths (3.50) pounds per gallon. (C) High-temperature coatings shall not exceed a VOC content offour and seventeen-hundredths (4.17) pounds per gallon. (D) Antifoulant coatings shall not exceed a VOC content of three and thirty-three hundredths (3.33) pounds per gallon. 

### t91 (E) Weld-through (shop) preconstruction primers shall comply with subdivisions (3) through (5). 

### fE-1 (F) Any other specialty coating shall not exceed a VOC content oftwo and eighty-three hundredths (2.83) pounds per gallon. (2) During application of any general use coating, VOC emissions shall be limited as follows:

(A) The VOC content of any general use coating shall not exceed two and eighty-three hundredths (2.83) pounds per gallon, as applied. (B) From May 1 through September 30, no thinner shall be added to any general use coating. (3) During application of any weld-through (shop) preconstruction primer, VOC emissions shall be limited throughout the year as follows: (A) Waterbased weld-through (shop) preconstruction primer shall be used. (B) The VOC content ofweld-through (shop) preconstruction primer, as applied, shall not exceed zero (0). (C) No cleaning material shall be used in the primer application facility. (D) No thinner shall be added to the weld-through (shop) preconstruction primer. (4) Ifthe owner or operator of a shipbuilding or ship repair facility determines that a waterbased weld-through (shop) preconstruction primer can no longer be used due to an operational, performance, or availability constraint associated with the waterbased weld-through (shop) preconstruction primer, the source shall do the

Date: Jun 19,2015 11 :08:02AM EDT DIN: 20150204-IR-326140441PRA Page 1Indiana Register following: (A) Notify the department within seven (7) days of discontinuing use ofthe waterbased weld-through (shop) preconstruction primer. (B) Submit to the department for approval a plan for an alternative control within sixty (60) days of discontinuance. The alternative control shall consist of one (1) ofthe following:

(i) A waterbased weld-through (shop) preconstruction primer. (ii) A control system with a minimum overall VOC emissions reduction efficiency of ninety-five percent (95%) that is subject to each ofthe following requirements:

(AA) The operation, maintenance, and testing requirements of 326 lAC 8-7-9. (BB) The monitoring, record keeping, and reporting requirements of 326 lAC 8-7-1 0. (C) Install the alternative control within nine (9) months of approval by the department ofthe plan required in clause (B). (5) During the time between the date when the owner or operator ofthe shipbuilding or ship repair facility discontinues the use ofthe waterbased preconstruction primer and the date when the alternative control is installed, the weld-through (shop) preconstruction primer used by the owner or operator of such shipbuilding or ship repair facility shall not exceed a VOC content of five and sixty-five hundredths (5.65) pounds per gallon or the VOC content for weld-through (shop) preconstruction primer prescribed by the U.S. EPA in a f.inal regulation establishing National Emissions Emission Standards for Shipbuilding and Ship Repair (Surface Coating), 40 CFR 63, Subpart II, whichever is lower. (b) On and after May 1, 1996, A source subject to this rule shall comply with the following work practice standards: (1) Cleaning accessories, such as, but not limited to, paper, cloth, and rags that have been used for cleaning surfaces and equipment and that contain cleaning materials shall be stored in normally closed gasket sealed containers. (2) VOC-containing solvents and coatings shall be stored in normally closed sealed containers prior to use. Spent VOC-containing solvents and coatings shall be stored in normally closed gasket sealed containers. (3) Cleaning materials for cleaning spray equipment, including paint lines, shall not be used unless the equipment for collecting the cleaning materials and minimizing its evaporation to the atmosphere is used. (4) All handling and transfer of VOC-containing materials to and from containers, tanks, vats, drums, and piping systems shall be conducted in a manner that minimizes drips and spills, and any drips and spills shall be cleaned up promptly. (5) All containers, tanks, vats, drums, and piping systems shall be free of cracks, holes, and other defects and must be closed unless materials are being added to or removed from them. (c) The owner or operator of sources subject to this rule shall comply with the following training requirements: (1) On or before January 1, 1996, the owner or operator shall develop a written worker training program. The training program shall be included in the compliance plan required to be submitted to the department for review by section 7(b)(1) ofthis rule. (2) On or before May 1, 1996, all workers, including contractors, shall have completed a training program if they engage in any ofthe activities listed in subdivision (3). (3) The training program may include trail)ing provided by the manufacturer or supplier of coatings, cleaning materials, or the application equipment thereof, and shall include written procedures, hands-on demonstration, as appropriate, and certification by the trainer ofthe trainee's ability to perform the task, on the following activities: (A) Identification of appropriate coatings or cleaning materials. (B) Preparation of coatings or cleaning materials according to coating or cleaning material manufacturer, distributor, or owner or operator's recommendations. (C) Application of coatings or cleaning materials, or organic solvents using techniques that minimize their usage. (D) Procedures to clean spray guns to minimize evaporation of organic solvents to the atmosphere. (E) Work practice standards established in subsection (b). (F) Procedures to gather, record, monitor, and report data in accordance with section 7 of this rule. (4) Beginning in 1997, the owner or operator shall provide annual refresher training prior to May 1 to any worker performing one (1) or more ofthe activities listed in subdivision (3). Such training shall be appropriate to the job responsibilities ofthe worker. (5) Any worker may perform one (1) or more activities listed in subdivision (3), for not more than one hundred eighty (180) days, notwithstanding the requirement of subdivision (2), provided: (A) such untrained worker works under the supervision of a worker who meets the training requirements of subdivision (2); and

Date: Jun 19,2015 11 :08:02AM EDT DIN: 20150204-IR-326140441PRA Page 2Indiana Register (B) the owner or operator keeps records of:

(i) the date the worker was assigned to the activity; (ii) the date training was completed; and (iii) the name ofthe worker providing the supervision. (6) The owner or operator shall keep records ofthe training program. The records shall consist ofthe following: (A) The date training was completed. (B) A list of workers by name and worker activities listed in subdivision (3) in which each worker has been trained. (C) A statement signed by the person providing the training certifying that the worker completed training and is proficient in the activities listed in subdivision (3) in which the worker will be engaged. (Air Pollution Control Division; 3261AC 8-12-4; filedApr 1, 1996, 10:00 a.m.: 191R 1753; filed Jun 15, 2001, 12:08 p.m.: 241R 3613)

Notice of Public Hearing

Posted: 02/04/2015 byLegislative Services Agency An html version ofthis document.

Date: Jun 19,2015 11 :08:02AM EDT DIN: 20150204-IR-326140441 PRA Page 3Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION

Notice ofPublic Hearing Notice of Public Hearing LSA Document #14-441

Under IC 4-22-2-24. IC 13-14-B-6. and IC 13-14-9, notice is herebygiven that on March 11, 2015, at 1:30 p.m., at the Indiana Government Center South, 302 West Washington Street, Conference CenterRoom A, Indianapolis, Indiana, the Environmental Rules Board will holda public hearing on amendments to 3261AC B-12-4 concerning antifoulant coatings used at shipbuilding and ship repair facilities. The purpose ofthis hearing is to receive comments from the publicprior to final adoption ofthese rules by the board. All interestedpersons are invited and will be given reasonable opportunity to express their views concerning the proposed amendments. Oral statements will be heard, but, for the accuracy ofthe record, all comments should be submitted in writing. Additional information regarding this action maybe obtained from Susan Bem, Rules Development Branch, Office ofLegal Counsel, (317) 233-5697 or(BOO) 451-6027 (in Indiana). Individuals requiring reasonable accommodations forparticipation in this event should contact the Indiana Department ofEnvironmental Management, Americans with Disabilities Act coordinatorat: Attn: ADA Coordinator Indiana Department ofEnvironmental Management Indiana Government CenterNorth 100 North Senate Avenue Indianapolis, IN 46204-2251 orcall (317) 233-17B5 (V). Speech and hearing impaired callers may contact IDEM via the Indiana Relay Service (711) or(BOO) 743-3333. Please provide a minimum of72 hours notification. Copies ofthese rules are now on file at the Rules Development Branch, Office ofLegal Counsel, Indiana Department ofEnvironmental Management, Indiana Government CenterNorth, 100 North Senate Avenue, Thirteenth Floorand Legislative Services Agency, Indiana Government CenterNorth, 100 North Senate Avenue, Room N201, Indianapolis, Indiana and are open forpublic inspection. Nancy King, Chief Rules Development Branch Office of Legal Counsel

Posted: 02/04/2015 byLegislative Services Agency An html version ofthis document.

Date: Jun 19,2015 11 :09:05AM EDT Dl N: 20150204-1 R-326140441 PHA Page 1

### 1 2 3 

### 4 5 

### 6 7 

### 8 9 

### 10 11 12 13

'\ 

### 14 15 INDIANA**EWVIRONMENT~~** 

### RULES BOARD INDIANA GOVERNMENT CEijTER SOUTH ' 

### 302 WEST**WASHINGTO~** 

### STRE$T INDIANAPOLIS, INDIANA MARCH 11,**20~5** 

### - 1:30 P.M.

MEMBERS PRESENT:

Chair Beverly Gard-General Public 

# ORIGINAL

Vice Chair William Etzler-Small Business Ken Rulon-Agriculture ·Gail**Boydston~Manufacturing**



### Tom R. Anderson-Environmental Interests Chris**Horn~Labor** 

### Gary Powdrill-General Public Dr. Ted Niemiec-Medical Kelly Carmichael-Public Utilities Dr. Joanne**Alexandrov~ch~Local** 

### Government ,· .. 

### Calvin Davidson-Proxy ISDH Dayid Bausman, Pr<;>x-y Lt. Governor for ISDA Cameron Clark-Director of IDNR Pam Fisher-Proxy IEDC Carol Comer (nonvoting member)-IDEM

16 The meeting was held on the 11th day of 17 MARCH, 2015, at 1:30 p.m., at.the**Indi~na** 

### Government 18 Center South, Conference Room A, Indianapolis, 19 Indiana, and reported by me, Marjorie A. Addington, 20 Notary Public in and for the County. of Hamilton, 21 State of Indiana, CM, CSR: KS. 22 23 24 25 ACCURATE REPORTING OF INDIANA William F. Daniels Prop. RPR/CP CM 12922**Br~ghton** 

### Avenue Carmel, Indiana 46032 (317) 848-0088 :}.

# ) 1 

### MADAM CHAIR GARD: It'S 1:30, ·so I think ( i 

### 2 we'll go ahead and ·call the E.nvironmental Rules Board 3 

### to order, it's March the 11th, 2015. It looks like 4 

### we have a quorum present. I'm going to go around, as· 5 usual, and ask the Board members to give their name 6 and who they represent. 7 

### MS. COMER: Start with me? 8 

### MADAM CHAIR GARD: Yes. Ms.·coMER: My name's Carol Comer, I'm Chief 10 of Staff and I'm here representing IDEM on behalf of 11 our Commissioner, Tom Easterly. 12 MADAM CHAIR GARD: And Carol has just 

# }

,. 

### 13. recently been**n~~ed** 

### Chief of ·staff. ( c 

### She was head 'of 14 the legal department before that, so welcome. 15 MS. COMER: Thank you. 16 DR. NIEMIEC: Ted Niemiec representing health 17 care providers. 18 

### MR. BAUSMAN: David Bausman, serve as proxy 19 for Lieutenant Governor. 20 MR. CLARK: Cam Clark here as the Director 21 for the Department of Natural Resources. 22 MR. CARMICHAEL: Kelly Carmichael 23 representing public utilities. 24 · MS. FISHER: Pam Fisher, proxy for**Sec~etary** 1 

### 25 of Commerce, Victor Smith.

### I I

I

. .r

-{ i I 

### 1 ,**~S.** 

### BOYDSTON:**G~il** 

### ?oy¢ston representing 2 industry. 3 

### MADAM CHAIR GARD: Beverly Gard,**gene~al** 

### 4 public. 5 MR. ETZLER: Bill Etzler, small business. 6. 7 

### MR. ANDERSON: Tom Anderson, environmental. MR. POWDRILL: Gary Powdrill, general public. 8 

### MR.**RULON~** 

### Ken Rulon, agriculture. 

### 9 DR. ALEXANDROVICH: Joanne Alexandrovich, 10 local government. 11- 

### l-2 13 14 15 16 17 18 19 

### 20 21 22 23 

### 24 2!) 

### MR. DAVIDSON: Calvin Davidson, solid waste. MR

.. HORN: Chris .Horn, labor. MADAM CHAIR·GARD: Thank you all**ve~y** 

### much

. First order of business today is the approval of the summary of the January 14th, 2015 Board meeting. Are there any additions or corrections to the summary as it was presented to you? (No response.) MADAM CHAIR GARD: If not, is there a motion to approve the minutes as distributed? MR. RULON: So moved. MADAM CHAIR GARD: Is there a second? MR. ANDERSON: Second. MADAM CHAIR GARD: All in favor say "aye." (All .respond "aye".) 

### 3

# )

- .·' 

### 4

1 

### MADAM CHAIR GARD: Opposed "nay". 2 

### (No response.) 3 

### MADAM CHAIR GARD: The minutes are approved. 

### 4 IDEM reports. First order of business, Carol, you're 5 up. 6 

### MS. COMER: 1hank you. I just wanted to 7 update the Board on s6me of the legislation that is 8 oc6urring at the present.**·s~nate** 

### Bill 312 is now, of 9 course{ in the House and it's the aboveground storage 10 tank bill. As·you'ie**prob~bly** 

### aware, it's no longer 11 

### our bill, btit what'S**h~ppening** 

### now is 

### it exempts 12 tanks that are already reported to another agency.

I \,\ 

### .13 IDEM is· tasked with compilirig information from other 

### 14 entities and streamlining that information, and also 15 it defines a critical zone of concern for water 

### 16 planning**purpose~.** 

### 17 For the Boar4's**perspecti~e,** 

### under the bill 18 as it currently stands, the Board will have to expand 19 on what tanks should be included in the bill, what 20 areas should be included-in the critical zone, and 21 also create categories of hazards related to those 22 tanks. 23 So 311 is our oversight cost bill and that's 24 

### moving forward, and also 350 

### is the omnibus bill andr 25 there are several things related to IDEM in thatI I

/

J 

## , 1 

### 2 3 

### 4 5 

### 6 7 8 

### 9 

### 10 11 12 13 14 15 

### 16 17 

### 18 19 20**M~~** 

### POWDRILL: Xes. MADAM CHAIR GARD: Mr. Anderson. MR. ANDERSON: Yes: MADAM CHAIR GARD: Mr. Etzler. MR. ETZLER: Yes. MADAM CHAIR GARD: Ms. Boydston. MS. BOYDSTON: Yes. MADAM CHAIR GARD: Mr. Davidson. MR. DAVIQSON: Yes. MADAM CHAIR GARD: Mr. Horn. MR. HORN.: Yes. MADAM CHAIR GARQ: 

## Ms. Fisher. MS. FISHER: Yes. MADAM CHAIR GARD: Mr. Bausman. MR. BAUSMAN: Yes. MADAM CHAIR GARD: Mr. Clark. MR. CLARK: Yes. MADAM**CH~IR** 

### GARD: Dr.**Niem~ec.** 

### DR. NIEMIEC: Yes. MADAM CHAIR GARD: Did I forget anybody? The 21 Chair votes aye. The rule is adopted 14 t6 zero. 22 

### 23 

### 24 Okay, this is a public hearing before the Environmental Rules Board of the State of Indiana concerning final adoption of amendments to rules at 25 326 IAC 8-12-4 regarding shipbuilding and ship

### 29

1 

### repair. . I now introduce Exhibit B, the preliminarily, 1 

### 2 adopted rules with IDEM's suggestive changes 3 

### incorporated into the record of the hearing. Susan, 4 do you want to present the rule? 5 

### MS. BEM: This rulemaking amends the volatile 6 organic compobnd limit for ahtifoulant coatings from 7 2.83 pounds.per gallon to 3.3 pounds per gallon in 8 326 IAC 8-12, the shipbuilding and ship repair rule. 9 The amended limit is consistent with the limit in the 10 final NESHAP at 40 CFR 63, subpart double "i," Table 11 2, and the CTG, EPA's Control Technique Guidelines, 12 issued on August 27, 1996. 

# ')

..• 

### 13

. There is one set of changes to this. rule ( \ 

### 14 from preliminary adoption to what was proposed from 15 the proposed rule. The four obsolete date references 16 in·subsections Band C are being proposed for. 17 deletion. Once again, this is also part of our 18 Indiana State Implementation Plan and will be 19 submitted to EPA for SIP approval once it's final and 20 effective. The Department requests that the Board 21 final adopt the rule as presented. Thank you. Any 22 questions? 23 MADAM CHAIR GARD: Any questions for Susan? 24 

### (No response.) I

. 

### 25 MADAM CHAIR GARD: Thank you. There are no(I

I.

I 

### .·

J / 1 

### 2

... 3 4 5 6 

### 7 8 

### speaker cards. Is there anyone in the audience that wishes to comment on the rule? (No response.) MADAM CHAIR GARD: The hearing is concluded. The Board will now consider final adoption of amendments to the shipbuilding rules in 326 IAC 8-12-4. Is there further Board discussion?

. (No response.) 30



### 9 MADAM CHAIR GARD: Is there a m6tion to adopt 10**IDEM'~ suggesti~e**  

### changes? 11 

### MR. POWDRILL: Madam Chair, I do believe we 12 need to adopt the changes as 1.3 

### 14 MADAM ·cHAIR GARD: That's wpat we're MR

..POWDRILL:

-- as a separate ..,-- as a 15 separate

-- 16 

### 17· 18 19 20 

### 21 22 23 24 25 

### MADAM CHAIR GARD: That's what we're doing. MR.**POWDRILL~** 

### Okay, I'm sorry. MR. ETZLER: So moved. MR. RULON: Second. MADAM CHAIR GARD: All in favor say "aye". (All respond "aye".) MADAM CHAIR GARD: Opposed "nay". (No response.) MADAM CHAIR GARD: The changes are adopted. Is there a motion to finally adopt the rule as1 

### 2 3 

### 4 5 6 7 8 9 

### 10 11 12 13 14 15 

### 16 17 18 19 20 

### 21 22 

### 23 

### 24 

### 25 amended?MR. ANDERSON: I move for final adoption. MADAM CHAIR GARD: Is there a second? MR. POWDRILL: Second. MADAM CHAIR GARD: Mr. Rulon. MR. RULON: Yes. MADAM CHAIR GARD: ·**Dr~** 

### Alexandrovich. DR. ALEXANDROVICH: Yes. MADAM CHAIR GARD: Mr. Carmichael.**MR~** 

### CARMICHAEL: Yes. MADAM CHAIR GARD: Mr. Powdrill.**~MR.** 

### POWDRILL: Yes. MADAM CHAIR GARD: Mr. Anderson. MR. ANDERSON:**Yes~** 

### MADAM CHAIR GARD: Mr. Etzler. MR. ETZLER: Yes. MADAM CHAIR GARD: Ms. Boydston. MS. BOYDSTON: Yes. MADAM CHAIR GARD: Mr. Davidson. MR.· PAVIDSON: Yes. MADAM CHAIR GARD: Mr. Horn. MR. HORN: Yes. MADAM CHAIR GARD: Ms. Fisher. MS. FISHER: Yes. MADAM CHAIR GARD: Mr. Bausman. 31 ( :



### \

.\I.

I '.

I i -'. /



### .J

) 

### 32

1 MR. BAUSMAN: Yes. 2 

### MADAM CHAIR GARD: Mr. Clark. 3 

### MR. CLARK: Yes. 4 

### MADAM CHAIR GARD: Dr. Niemiec. 5 

### DR. NIEMIEC: Yes. 6 

### MADAM CHAIR GARD: The Chair votes aye. The 7 rule is adopted 14 to.zero. 8 This is a public hearing before the 9 Environmental Rules Board of the State of Indiana I 

### 10 concerning final adoption of amendments to rules at 11 326 IAC 6.5 and 6.8, particulate matter ·emission 12 limits. I will now introdu·ce Exhibit 

## c, the 13 

### prelimfnarily adopted rules with IDEM's suggestive 14 changes incorporated, into the record of the hearing. 15 

### MS. BEM: This rulemaking amends source 16 specific emission limits within Indiana's rules 17 concerning particulate matter at 326 IAC 6.5 and 326 18 

### IAC 6.8. There are two**ch~nges** 

### since preliminary 19 adoption. 20 The source name at 326 IAC 6.5-5-2 in Howard 21 County is now FCA US, formerly Chrysler Group, and 22 the language at 326 IAC 6.8-2-32 was amended to make 23 it clearer that the new limit is a total limit that 24 

### applies to all the pulp dryers listed in the rule. 25 Also the typo for the word "molded" was corrected,.(I I 

### )



## )

) 172

1 

### (.No**r~sponse.)** 2 

### MADAM CHAIR GARD: The motion passes and I 3 will get to work on that and you all will be advised 4 as to the makeup. 5 

### Did anybody order supper? Open forum. Is 6**t~ere.** 

### anybody that wishes to address the Board, at

. '

. . 

### 7 

### your own**ris~?** 

### 8 (No response.) 9 

### MADAM CHAIR GARD: Well, the next·meeting of 10 the Environmental Rules**Bo~rd** 

### has not been scheduled, 11. ,but I believe it will**~e** 

### Wednesday, June the lOth or 12 Wednesday, July the 8th, at 1:30 in this conference 13 room, and you:will be notified as soon as**~hat** 

### date 14. 

### is ;determined. Is there a**m~tion** 

### to adjourn?. 15 DR. NIEMIEC: $o moved. 

### 16 MR. RULON: Second. 17 MADAM CHAIR GARD: All in favor say "aye". 18 (All respond "aye".) 19 

### MADAM CHAIR**G~RD:** 

### "Nay." 20 (No response.) 21 MADAM CHAIR**GARD:-~-fie** 

### meeting is adjourned. 

### 22 (WHEREUPON, at**5:30p.m~,** 

### March 11, 2015, 23 this hearing concluded for the day.) 24 

### 25

# )



# ,) 173

1 

### CERTIFICATE ( 1. 2 

### 3 STATE OF INDIANA ss: 4 

### COUNTY OF HAMILTON 5 

### '6 I, Marjorie A. Addington, the undersigned Court Reporter and Notary Public residing and maintaining 7 offices in the City of Carmel, Hamilton County, Indiana, do hereby certify: 8 9 

### 10 That I**r~ported** 

### to the**b~st** 

### of my ability in machine shorthand all of the words spoken by all parties in 11 attendance during the course of the hearing; 12 13 

### 14 15 16 17 

### That I later reduced my shorthand notes into the foregoing typewritten transcript form, which typewritten transcript is a true record to the best of my ability of the hearing;

That I am not a relative or employee or attorney or 18 counsel of any of the parties, nor am I a relative or an employee of such attorney or counsel, and that I 19 am not financially**irit~rested** 

### in this action. 20 21 22 23 

### 24 25 IN WITNESS HERETO, I have affixed**Not~rial** 

### Seal and subscribed my signature below this 21st day of MARCH, 2015. my

# ~,6v Notary Public County of Residence: Hamilton

# ~ali My Commission Expires on: August 22,**2~is** ' ' \

.

### 07/2015 Shipbuilding Antifoulant Coatings 110(1) Demonstration- SIP Submittal for 326 lAC 8-12-4 

### 1. Antifoulant VOC emissions A) Jeftboat 2,580 gallons per year ofantifoulant coatings (based onthe maximum number ofbarges that require antifoulant coatings for two types ofbarges) 2,580 gallons X 2.83 lbs VOC/gallon coating= 3.65 tons per year VOC B) VOC content limits in solids basis Current limit: 2.83 lbs VOC/gallon coating 2.83 lbs VOC/gallon coating X 1/7.36lb VOC/gallon VOC = 0.38 gallon VOC/gallon coating 1-0.38 gallon coating= 0.62 gallon solids/gallon coating 2.83 lbs VOC/gallon coating 

### I 0.62 gallon solids/gallon coating= 4.6 lbs VOC/gallon solids New limit: 3.33 lbs VOC/gallon coating 3.33 X 1/7.36 = 0.45 gallon VOC/gallon coating 1-0.45 gallon coating= 0.55 gallon solids/gallon coating 3.33 

### I 0.55 = 6.08lbs VOC/gallon solids %difference: new limit is 32% higher than old limit C) Estimated increase in VOC emissions Increase in emissions= 3.65 X 32% = 1.17 tons VOC per year 

### 2. Offsets from Architectural and Maintenance (AIM) Coatings Rule at 326 lAC 8-14

AIM Coatings offset were estimated as the difference between the Federal AIM rule and the OTC Model Rule and Wisconsin Traffic markings as found in LADCO (MWRPO) guidance "Source Category: Architectural and Industrial Maintenance Coatings". From Table 3 ofthe LADCO guidance Year Control Measure CE(%) 2002 (Base) and 2003- Federal AIM rule: 2008 Arch. Coatings Solvent-based 20 Arch. Coatings Water-based 20 Traffic Markings 20 Industrial Maint. Coatings 20 Special Purpose Coatings 20 Page 1 of3

### 07/2015

2009-2018 Federal AIM rule plus OTC Model Rule & 

### WI Traffic Markings Rule: Arch. Coatings All 38.8 Arch. Coatings Solvent-based 49.8 Arch. Coatings Water-based 20 Traffic Markings 56.4 Industrial Maint. Coatings 60.5 Special Purpose Coatings 60.5

Additional reductions due to OTC Model Rule County Tons/ Ton/ Total Federal Additional Reduction Offset Year SummDay Reduction AIM E F

A B (AIM and Reduction OTC) D



## c (A/365)* 1.3 [(B*C)-(D*B)]/[B-(D*B)] B*E Clark Architectural 128.97 0.4594 0.388 0.2 0.24 0.108 Clark Traffic 0.14 0.0005 0.564 0.2 0.46 0.0002 Markings Clark Industrial 33.24 0.1184 0.605 0.2 0.51 0.060 Maintenance Clark Special 3.53 0.0126 0.605 0.2 0.51 0.006 Purpose Floyd Architectural 87.26 0.3108 0.388 0.2 0.24 0.073 Floyd Traffic 0.08 0.0003 0.564 0.2 0.46 0.000 Markings Floyd Industrial 22.49 0.0801 0.605 0.2 0.51 0.041 Maintenance Floyd Special 2.39 0.0085 0.605 0.2 0.51 0.004 Purpose 0.292



### Notes: 1) Emission estimates are based on 2011 NEI Version 1. 2) Reductions and the summerday calculations are based on LADCO guidance "(Source Category: Architectural and Industrial Maintenance Coatings", 3/6/2006) available at http://ladco.org/reports/ control/white-papers/aim coatings.pdf. 3) The reductions are extrapolated since the LADCO white paper uses a 2009 inventory year and offsets are based on 2011. 4) AIM summerday calculations are based on average daily emissions using a multiplier of 1.3 using guidance from page 9 ofthe LADCO white paper. Other guidance does not use a multiplier of 1.3 but Page 

### 2 of3

### 07/2015

to be consistent with the LADCO white paper a 1.3 multiplier was used to calculate AIM ozone summer day emissions.



### 3. Antifoulant VOC Emissions Compared to Available AIM Reductions

1.17 tons per year= 0.004167 summerday estimate (ton/day) 0.292 AIM reductions (tons/summerday) (T/Sd) 0.0018 Credit for Stage II (T/Sd) (needed for Stage II offsets for 2014) 0.290 (T/Sd) Remaining 2014 Credits Note: A multiplier of 1.3 was used to calculate summer day emissions for antifoulant coatings to be consistent withthe multiplier used for AIM offsets. Jeffboat repmis that on an annual average they operate 6 days a week. IDEM does not have operating hours specific to the ozone season.

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