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: Reasonably Available Control Technology Update to Address 

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 Protection Agency (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 of the 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 of the 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 . 

CTDEP staff reviewed the inventory of sources for facilities with North American Industrial 

Classification System codes 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 of the three CTGs listed in Table 1 . 

Source category CTG document Document number 

Flat wood paneling coating Control techniques guidelines for flat EPA-453/R-06-004 

wood paneling 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. CTG Categories for Negative Declaration. 

(Printed on Recycled Paper) 

79 Elm Street e Hartford, CT 06106-5127 

www.ct .gov/dep 

An Equal Opportunity Employer 
Page 2 

Curtis Spalding 

April 29, 2010 

Equivalent Level of Control 

For the Control Techniques Guidelines for 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. RCSA section 22a-174-44 is based on a model rule of the Ozone Transport Commission 

(OTC). The OTC model 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 . 

RCSA section 22a-174-44 achieves VOC reductions 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 to the VOC content 

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. 

RCSA section 22a-174-44 includes all of the CTG-recommended approaches to controlling VOC 

emissions from the application and cleanup of miscellaneous industrial adhesives (adhesive VOC content 

limits, cleaning solvent VOC content limits, work practices, optional air pollution control equipment 

requirements, surface preparation, spray gun cleaning) and exceeds the recommendations of the CTG by 

establishing VOC content limits for sealants and sealant primers and by regulating sellers and 

manufacturers, not just appliers, of regulated adhesives, adhesive primers and sealants . The exemptions 

of RCSA section 22a-174-44 are similar to those recommended in the CTG. While there are minor 

differences in the named adhesive categories regulated in the CTG and RCSA section 22a-174-44,1 those 

differences are inconsequential compared to the inclusion of a number of categories 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 . 

CTG Requirements Underp-oing Regulatory Adoption 

CTDEP determined that regulatory revisions would be needed to address the requirements of the seven 

CTGs listed in Table 2, and CTDEP has completed the adoption of regulatory requirements consistent 

with six of the seven CTGs. Table 2 identifies the regulatory citation associated with each CTG. CTDEP 

will continue to pursue adoption of requirements consistent with the remaining CTG and, upon 

completion of the 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 VOC content limit and thus would 

regulate such adhesives at a higher VOC content than recommended in the CTG. RCSA section 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 

CTG document 

. 

CTG document Regulatory citation Status of regulatory revision 

number 

Control techniques EPA-453/ RCSA seetion April 6, 2010 

guidelines for industrial R-06-001 22a-174-20, new 

cleanin g 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) 

lette rpress printing _ 

Control techniques EPA-453/ RCSA section 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/ RCSA section April 6, 2010 

guidelines for large R-07-004 22a-174-20, new 

appliance coatings 2007/09 subsection (hh) 

Control techniques EPA-453/ RCSA section April 6, 2010 

guidelines for metal R-07-005 22a-174-20, revised 

furniture coatings 2007/09 subsection (p) 

Control techniques EPA-453/ RCSA section 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 mechanism through an amendment to RCSA section 22a-174-20 and one for the RACT 

update statement. 

Enforceable Mechanism 

The six adopted CTGs are now included in RCSA section 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 of the requirements of 40 CFR 51, Appendix V, Section 2. The public notice and 

certification of public 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: RCSA section 22a-174-20(p) (q)1ff), (u) (hh) and (ii) 

A-1 . Notice of public 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 RCSA sections 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 of the 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 of public hearing. 

B-3. Hearing report. 

To the extent quantifiable, CTDEP plans to incorporate expected VOC emission reductions from these 

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 . If you 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