# STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION April 29, 2010 H . Curtis Spalding, Regional Administrator U.S. Environmental Protection Agency EPA New

England Regional Office 5 Post Office Square - Suite 100 Boston, MA 02109-3912 Re: ReasonablyAvailable Control Technology Update toAddress Control Techniques Guidelines Issued in 2006, 2007 and 2008 Dear Administrator Spalding: On February 1, 2008, the Connecticut Department of Environmental Protection (CTDEP) submitted to the U.S. Environmental ProtectionAgency (EPA) an attainment demonstration for the 1997 8-hour ozone national ambient air quality standard (NAAQS)

. That attainment demonstration includes an analysis of how Connecticut complies with the reasonably available control measures and reasonably available control technology (RACT) requirements ofthe federal Clean Air Act . This letter is intended as a revision to the State Implementation Plan (SIP) concerning the RACT requirements for volatile organic compounds (VOC), given EPA's adoption of eleven control techniques guidelines (CTGs) in 2006 through 2008

. Pursuant to 40 CFR 51, Appendix V, Section 2.1(a), a copy of the final regulation implementing six ofthe CTGs and documentation of the public hearing is provided. For three other CTGs, this submission includes negative declaration statements, and, for one CTG, this submission includes a statement of equivalent level of control . Nezative Declarations CTDEP hereby submits negative declarations for the three source categories identified in Table 1 . For these three source categories, CTDEP has determined that there are no sources or no sources that meet the applicability threshold of the applicable CTG in Connecticut . CTDEPstaffreviewed the inventory of sources for facilities with North American Industrial Classification Systemcodes that correspond to the 2006 through 2008 CTG categories; interviewed its field staff

; and searched telephone directories and Internet web pages (including other state government databases) to determine if any sources meeting the applicability requirements for the 2006 through 2008 CTGs are located in the state. Staff has determined that there are no sources or no sources that meet the applicability thresholds for each ofthe three CTGs listed in Table 1 . Source category CTGdocument Document number Flat wood paneling coating Control techniques guidelines for flat EPA-453/R-06-004 wood p aneling coatings 2006/09 Fiberglass boat manufacturing Control techniques guidelines for EPA-453/R-08-004 fiberglass boat manufacturing materials 2008/09 Automobile and light-duty Control techniques guidelines for EPA-453/R-08-006 truck assembly coating automobile and light-duty truck 2008/09 assembly coatings Table 1 . CTGCategories for Negative Declaration.

(Printed on Recycled Paper) 79 Elm Street e Hartford, CT 06106-5127 www .ct .gov/dep An Equal Opportunity EmployerPage 2

Curtis Spalding April 29, 2010 Equivalent Level of Control For the Control Techniques Guidelinesfor Miscellaneous Industrial Adhesives (EPA 453/R-08-005 2008/09), CTDEP has determined that an equivalent level of control is satisfied with an existing air quality regulation, Regulations of Connecticut State Agencies (RCSA) section 22a-174-44. RCSA section 22a-174-44, concerning adhesives and sealants, was adopted on October 3, 2008 and submitted to EPA on November 18, 2008 as an appendix to the Annual Fine Particulate Matter Attainment Demonstration. RCSAsection 22a-174-44 is based on a model rule of the Ozone Transport Commission (OTC) . The OTCmodel rule is, in turn, based on a reasonably available control technology determination prepared by the California Air Resources Board in 1998 and regulations adopted in the California local air pollution control districts. RCSAsection 22a-174-44 achieves VOCreductions through two basic components: sale and manufacture restrictions that limit the VOC content of specified adhesives, sealants and primers sold in the state; and use restrictions that apply primarily to commercial/industrial operations. In addition tothe VOCcontent limits and use requirements, this section includes requirements for cleanup and preparation solvents and allows for compliance through the use of add-on air pollution control equipment . RCSAsection 22a-174-44 includes all of the CTG-recommended approaches to controlling VOC emissions fromthe application and cleanup of miscellaneous industrial adhesives (adhesive VOCcontent limits, cleaning solvent VOCcontent limits, work practices, optional air pollution control equipment requirements, surface preparation, spray gun cleaning) and exceeds the recommendations ofthe CTG by establishing VOC content limits for sealants and sealant primers and by regulating sellers and manufacturers, notjust appliers, of regulated adhesives, adhesive primers and sealants. The exemptions of RCSAsection 22a-174-44 are similar to those recommended in the CTG . While there are minor differences in the named adhesive categories regulated in the CTGand RCSA section 22a-174-44,1 those differences are inconsequential compared to the inclusion of a number ofcategories of sealants and sealant primers in RCSA section 22a-174-44, which are not included in the CTG, and the broader applicability of RCSA section 22a-174-44. CTDEP does not believe any RACT deficiency exists. CTGRequirements Underp-oing RegulatoryAdoption CTDEP determined that regulatory revisions would be needed to address the requirements ofthe seven CTGs listed in Table 2, and CTDEP has completed the adoption of regulatory requirements consistent with six ofthe seven CTGs. Table 2 identifies the regulatory citation associated with each CTG . CTDEP will continue to pursue adoption of requirements consistent with the remaining CTGand, upon completion ofthe process, will submit the revised regulation to EPA as a revision to the SIP.

' RCSA section 22a-174-44 does not include a general adhesive-to-wood VOCcontent limit andthus would regulate such adhesives at a higher VOCcontent than recommended in the CTG . RCSAsection 22a-174-44 does not include motor vehicle adhesives or motor vehicle weatherstrip adhesives, although comparable categories of adhesives are regulated in RCSA section 22a-174-40, concerning consumer products.Page 3

Curtis Spalding April 29, 2010

a e CTGdocument .CTGdocument Regulatory citation Status ofregulatory revision number Control techniques EPA-453/ RCSAseetion April 6, 2010 guidelines for industrial R-06-001 22a-174-20, new cleaning solvents 2006/09 subsection (ii) Control techniques EPA-453/ RCSA section April 6, 2010 guidelines for offset R-06-002 22a-174-20, new lithographic printing and 2006/09 subsection (gg) letterpress printing _ Control techniques EPA-453/ RCSAsection April 6, 2010 guidelines for flexible R-06-003 22a-174-20, new package printing 2006/09 subsection (ff) Control techniques EPA-453/ RCSA section April 6, 2010 guidelines for paper, film R-07-003 22a-174-20, revised and foil coatings 2007/09 subsection (g) Control techniques EPA-453/ RCSAsection April 6, 2010 guidelines for large R-07-004 22a-174-20, new appliance coatings 2007/09 subsection (hh) Control techniques EPA-453/ RCSAsection April 6, 2010 guidelines for metal R-07-005 22a-174-20, revised furniture coatings 2007/09 subsection (p) Control techniques EPA-453/ RCSAsection Draft prepared; undergoing preguidelines for R-08-003 22a-174-20, publication review miscellaneous metal and 2008/09 revision of plastic arts coatings subsection (s) Administrative Materials Two sets of public participation documents are included in this submission: one for the adoption of the enforceable mechanismthrough an amendment to RCSAsection 22a-174-20 and one for the RACT update statement . Enforceable Mechanism The six adopted CTGs are now included in RCSAsection 22a-174-20, either in amended or new subsections. The amendments and new requirements were processed through the administrative regulatory adoption process as a single project, and all required state and federal procedures for public participation were followed as evidenced in the attachments listed below . Such attachments are included in satisfaction ofthe requirements of 40 CFR 51, Appendix V, Section 2. The public notice and certification ofpublic hearing demonstrate that CTDEP held a public hearing in accordance with the public notice and that CTDEP followed appropriate state and federal procedures for public participation. The hearing report provided for each new subsection or amendment includes a summary of comments received and a description of changes made as a result of the comments. The submitted attachments include the following:

T bl 2 PTV_ C

ate ories Re uirin a Re ulato Update

Attachment A: RCSAsection 22a-174-20(p) (q)1ff), (u) (hh) and (ii) A-1 . Notice ofpublic hearing. A-2. Certification of public hearing. A-3. Hearing report .Page 4

Curtis Spalding April 29, 2010 Please note that sections 8 and 9 of the formal, legal-sized version of the amendment (pages 29-30) consist of revisions to RCSAsections 22a-174-32(b)(3) and 22a-174-33(f)(6), which are not being submitted for SIP approval . RACT Update Statement The RACT update, consisting ofthe statements of negative declaration and equivalency, was also subject to public notice, hearing and opportunity for comment, which is documented in Attachment B, as follows: Attachment B

: RACT Update Statement B-1 . Notice of public hearing. B-2. Certification ofpublic hearing. B-3. Hearing report. To the extent quantifiable, CTDEP plans to incorporate expected VOCemission reductions fromthese regulatory changes into the next round of revisions to the SIP for ozone. We look forward to working with EPA as a critical partner in our continuing mission to conserve, improve and protect the environment and public health for the citizens of Connecticut . Ifyou require additional information or have any questions about this submission, please get in touch with Ric Pirolli, Assistant Director, Engineering and Enforcement Division of the Bureau of Air Management. Sincerely yours,

Anne R . Gobin Chief, Bureau of Air Management cc: Anne Arnold, EPA Region I Robert McConnell, EPA Region 1 Ric Pirolli, CTDEP