ATTACHMENT 1 

Federal Standards Analysis Pursuant to Section 22a-6(h) of the General Statutes 

Pursuant to the provisions of section 22a-6(h) of the Connecticut General Statutes (CGS), the 

Commissioner of the Department of Environmental Protection (the Department) is authorized to 

adopt regulations pertaining to activities for which the federal government has adopted standards 

or procedures . At the time of public notice, the Commissioner must distinguish clearly all 

provisions of a proposed regulation that differ from federal standards or procedures. 

In accordance with the requirements of CGS section 22a-6(h), in the matter of the proposed 

amendment of sections 22a-174-20, 22a-174-32 and 22a-174-33(f) of the Regulations of 

Connecticut State Agencies (RCSA), the Department has performed a comparison of the 

proposed amendment with federal provisions, which is set out below. 

Regarding the revision of subsections (p) and (q) and adoption of subsections (ffl (gg) (hh) and 

(ii) in RCSA section 22a-174-20 : There are no comparable federal standards specifying a 

reasonably available control technology (RACT) level of control, although Clean Air Act section 

182(b) requires states to establish a RACT level of control for certain categories of sources. 

EPA does issue control technique guidelines (CTGs) that recommend work practices, application 

methods, reformulation and/or control equipment operation that EPA considers a RACT level of 

control for a source category or activity, but the adoption of enforceable requirements that meet 

at least that recommended level of control is left to each state with a nonattainment area for an 

ozone national ambient air quality standard . In general, the proposed requirements for offset 

lithographic and letterpress printing, industrial cleaning solvents, flexible package printing, metal 

furniture coating, large appliance coating and paper, film and foil coating are consistent with the 

recommendations of the CTGs and provide at least a RACT level of control . 

The deletion of the reactivity-based architectural coating requirements of subsections (g), (h) and 

(i) of RCSA section 22a-174-20 aligns RCSA section 22a-174-20 with the adoption in July 2007 

of more comprehensive requirements to limit emissions from paints in RCSA section 22a-174-

41 . There are federal standards for architectural coatings but those standards, in 40 CFR 59 

Subpart D, regulate fewer coating categories than those in RCSA section 22a-174-41 and 

otherwise differ, as follows : 

Subpart D applies to nationwide architectural coating manufacturers, importers and 

distributors while RCSA section 22a-174-41 applies to any person "who sells, supplies, 

offers for sale or manufactures for sale in the State of Connecticut on or after May 1, 

2008 any architectural coating for use in the State of Connecticut and to any person who 

applies or solicits the application of any architectural coating within the State of 

Connecticut on or after May 1, 2008 . 

" The definitions for the regulated coating categories differ in some respects between the 

two rules . 
41 

. 

. 

For the categories that are regulated under both rules, all of the limits in RCSA section 

22a-174-41 are at least as stringent and many of the limits in RCSA section 22a-174-41 

are more stringent than the federal limits . 

All of the VOC limits in Subpart D have an effective date of December 10, 1998, 

whereas the VOC limits in RCSA section 22a-174-41 are effective on May 1, 2008 for 

most regulated product categories. 

Regarding the addition of subsection (ii) to RCSA section 22a-174-20 : New subsection (jj) 

regulates the cleaning of spray application equipment at any facility where spray application 

equipment is used. There are no general federal requirements regulating the cleaning of spray 

application equipment. EPA does specify spray application equipment cleaning requirements for 

certain source categories in 40 CFR 63, national emissions standards for hazardous air pollutants, 

and aerospace manufacturing facilities that are subject to such requirements in 40 CFR 63 are 

exempt from the general spray application cleaning requirements proposed in subsection (jj) . 

RCSA section 22a-174-32 defines a RACT level of control for volatile organic compound 

emissions from certain activities not regulated in RCSA section 22a-174-20. The revision to the 

applicability requirements of RCSA section 22a-174-32(b)(3) takes into account the 

establishment of RACT levels of control for several source categories in subsections (fl) through 

(ii) of RCSA section 22a-174-20. As the CTGs generally recommend that only one set of RACT 

level controls apply to a given source category, the revision is consistent with the approach 

recommended in federal guidelines, although no analogous federal standards or procedures exist. 

RCSA section 22a-174-33(fl establishes the timing requirements for the submission of Title V 

permit applications . Subdivisions (1) through (5) include the timing requirements in general, for 

submission of applications concerning new sources, modifications and renewals. Subdivision (6) 

includes specific application submission timing requirements for Acid Rain sources, namely 

those required of Acid Rain program sources in 40 CFR 72.30 . The amendment eliminates the 

reference to the federal application submission requirements for Acid Rain program sources, as 

those requirements apply independently. 

December 9. 2008 /s/Merrily A. Gere 

Date Merrily A. Gere 

Bureau of Air Management